1058 Cherokee Nation, 480 U.S. at 704; Rands, 389 U.S. at 123; United States v. Kan. City Life Ins. Co., 339 U.S. 799, 804 (1950); see Lucas, 505 U.S. at 1028-29; United States v. 30.54 Acres of Land in Greene Cty. (Filiaggi), 90 F.3d 790, 795 (3d Cir. 1996) (“Exercise of the servitude did nothing more than realize a limitation always inherent in the landowners’ title. It was not a taking.”); Pub. Util. Dist. No. 1 v. City of Seattle, 382 F.2d 666, 669 (9th Cir. 1967) (“[T]he navigational servitude, by its nature, does not destroy or exclude all property rights in the beds and banks of navigable streams. Such rights continue to exist but are held subject to the governmental power in the nature of an easement.”).