Horne v. Dep’t of Agric., 135 S. Ct. 2419, 2432 (2015) (“clear and administrable rule for just compensation”); United States v. 564.54 Acres of Land (Lutheran Synod), 441 U.S. 506, 511 (1979) (“relatively objective working rule . . . a useful . . . tool”); Kimball Laundry, 338 U.S. at 5 (“a fair measure of public obligation to compensate the loss incurred by an owner as a result of the taking of his property for public use”);