In the Blair v. City of Chicago case in 1905, the U.S Supreme Court ruled on a dispute over property rights and eminent domain. The city of Chicago had taken land owned by Edward Blair for public use without providing just compensation, which Blair argued was a violation of his Fifth Amendment rights. The court held that while governments have the power to take private property for public use under eminent domain, they must provide "just compensation" to the owner as required by the Constitution's Takings Clause. However, it also stated that what constitutes "just compensation" is not always equivalent to market value and can be determined through other means such as benefits conferred upon remaining lands or properties due to improvements made possible by condemnation proceedings. In this particular case though, since no special benefits were conferred upon Mr.Blair’s remaining lands due to these proceedings he was entitled full monetary recompense from City of Chicago.

In the dissenting opinion for Blair v. City of Chicago, Justice Harlan argued that the city's actions constituted a taking of private property without just compensation, violating the Fourteenth Amendment. He contended that when a public entity alters its use of an easement in a way that significantly increases burdens on the servient estate (the land over which an easement is held), it amounts to additional taking for which compensation must be paid. In this case, he believed that replacing horse-drawn cars with electric trolleys represented such an alteration and increased burden due to noise and vibration caused by heavier vehicles moving at higher speeds. Therefore, according to Justice Harlan’s view, even though there was no physical invasion into Blair's property beyond what had been initially granted in terms of right-of-way for street railway purposes, this change should have triggered constitutional protections against uncompensated takings.