Prior opinions issued by the United States Supreme Court contained dicta pertaining to government land-use regulations. See Agins v. City of Tiburon, 447 U.S. 255 (1980). Specifically, the dicta suggested that such regulations must “substantially advance legitimate state interests” in order to satisfy the Fifth Amendment’s Takings Clause. The United States Court of Appeals for the Ninth Circuit relied on that dicta when it found that a Hawaii law prohibiting oil companies from charging gas-station operators more than a specific rent amount did not serve the state’s legitimate interest in keeping gas prices under control. The case was appealed to the United States Supreme Court.