Answer:
Barron v. Baltimore's simple rule, that the Bill of Rights applies only to the federal government and not to the states, was, in the words of Chief Justice Marshall, "not of much difficulty" -- self-evident from the structure and literal language of the Constitution. However, in spite of the Court's ruling, state courts still interpreted the Bill of Rights as applying to their own governments, viewing them as reflections of the general laws in Anglo-American culture ("the common law"). The Supreme Court's ruling in Barron prevailed in federal courts, however, until passage of the Fourteenth Amendment after the Civil War. Gradually since then, the Supreme Court has interpreted the Fourteenth Amendment, which bans states from depriving citizens of life, liberty, or property without "due process of law," as also incorporating -- or applying -- most of the amendments in the Bill of Rights against the states, including the "takings clause" of the Fifth Amendment. Modern constitutional law prohibits state governments from taking private property without just compensation.
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