<P> Similar bills have subsequently been put forth in the House of Representatives by Congressman Dennis Rehberg (R - MT), Tom DeLay (R - TX), and John Conyers (D - MI) with James Sensenbrenner (R - WI). As some small - scale eminent domain condemnations (including notably those in the Kelo case) can be local in both decision and funding, it is unclear how much of an effect the bill would have if it passed into law . This bill has been reintroduced several times . </P> <P> In 2008, land use Professor Daniel R. Mandelker argued that the public backlash against Kelo is rooted in the historical deficiencies of urban renewal legislation . In particular, the article cited the failure to incorporate land use planning and a precise definition of blight in urban renewal legislation as problematic . In 2009, Professor Edward J. Lopez of San Jose State University studied passed laws and found that states with more economic freedom, greater value of new housing construction, and less racial and income inequality were more likely to have enacted stronger restrictions sooner . </P> <P> Severe criticism of the Kelo decision came from Professor Gideon Kanner of the Loyola Law School, Los Angeles . </P> <P> Prior to Kelo, eight states specifically prohibited the use of eminent domain for economic development except to eliminate blight: Arkansas, Florida, Kansas, Kentucky, Maine, New Hampshire, South Carolina and Washington . As of June 2012, 42 states had enacted some type of reform legislation in response to the Kelo decision . Of those states, 22 enacted laws that severely inhibited the takings allowed by the Kelo decision, while the rest enacted laws that place some limits on the power of municipalities to invoke eminent domain for economic development . The remaining eight states have not passed laws to limit the power of eminent domain for economic development . </P>

In kelo v. new london the kelos did not believe the fifth amendment applied to taking land to