 In several decisions of the late 1930s and 1940s, as shown in footnote 4 of the Carolene Products decision, the Supreme Court came to see property rights as deserving of less protection than other measures in Constitution.Starting in 1937, both the country and its courts began to concentrate on personal liberties, and especially the meaning of the Equal Protection Clause of the Fourteenth Amendment.The Supreme Court first held that state regulations that go too far may effect a taking in the 1922 case of "Pennsylvania Coal Co. v. Mahon".