 She argued that the decision eliminates "any distinction between private and public use of property—and thereby effectively delete[s] the words 'for public use' from the Takings Clause of the Fifth Amendment".A number of states, in response to "Kelo", have passed laws and/or state constitutional amendments which make it more difficult for state governments to seize private land.Takings that are not "for public use" are not directly covered by the doctrine, however such a taking might violate due process rights under the Fourteenth amendment, or other applicable law.