1055 Gibson v. United States, 166 U.S. 269, 272 (1897); s ee Lucas v. S.C. Coastal Council, 505 U.S. 1003, 1028-29 (1992) (“a pre-existing limitation upon the land owner’s title”); Rands, 389 U.S. at 123 (“a power to which the interests of riparian owners have always been subject”); Scranton v. Wheeler, 179U.S. 141, 163 (1900); see also Lambert Gravel Co. v. J.A. Jones Constr. Co., 835 F.2d 1105, 1112 (5th Cir. 1988); cf. Ronald C. Allen, Federal Evaluation of Riparian Property: Section 111 of the Rivers and Harbors Act of 1970, 24 me. l. reV. 175, 197-98 (1972) (“[The] servitude exemplifies the only clear cut instance when we as a nation have maintained a common property right exclusively for common benefit when needed.”).