Regarding individual constitutional rights, a landmark decision in the realm of mitigating property damage in flood-prone areas was a 1978 federal district court ruling (sustained on appeal to the Supreme Court) upholding the federal flood insurance program. In Texas Landowners' Rights Association v. Harris, plaintiff landowners sued the federal agency administering the national flood insurance program, because the program required that flood-prone communities engage in flood plain land use management for the purpose of mitigating property damage, and denied federal financial assistance in property acquisition (e.g., FHA loans) for the purchase of property in flood-prone areas in which such land use planning did not exist. Since the denial of federally assured financing for property purchases in flood-prone communities not engaged in flood plain management had the effect of reducing property values in these communities, landowners sued the United States on the theory that their lost property value constituted a taking of their property by the federal government. In rejecting this argument, the court thereby upheld government authority to require community and individual disaster mitigation measures as a condition for federal financial assistance in property acquisition and restoration subsequent to a flood-related disaster. (Burton, The Constitutional Roots of All-Hazards Policy, Management, and Law, 2008, p. 9)