Id. at 584. In a regulatory inverse taking case, the Supreme Court recently rejected the contention that the effects of general regulatory activity—such as higher consumer demand due to government enforcement of quality standards and promotional activities—can offset the total just compensation due for a specific physical taking. Horne , 135 S. Ct. at 2432. The Court expressly clarified that this ruling, concerning certain regulatory benefits, does not affect the deduction of special benefits from the amount of compensation paid in partial takings. Id. (discussing concerns raised in dissent); see id. at 2435-36 (Breyer, J., concurring in part and dissenting in part) (“it is unclear to me what distinguishes this case from . . . other types of partial takings”).