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7. Ornstein <br />Lge 8 <br />.thdrawal liability <br />out of proportion. <br />L. at 226. <br />C. <br />actually imposed on an employer will always <br />to its experience with the plan ." <br />The third factor in analyzing a taking challenge, is the <br />effect of the regulation on the property owners distinct <br />investment -backed expectations. These expectations must be <br />reasonable. Connollv, 106 S. Ct. at 1027. The Supreme Court <br />also has noted that "perhaps because of its vary uncertainty, the <br />interest in anticipated gains has traditionally been viewed as <br />less -compelling than other property -related interests." Andrus, <br />100 S. Ct. at 327. <br />The Connollv case is particularly instructive on this point <br />because it too involved direct monetary payments. In analyzing <br />this factor of the taking test, the court noted that pension <br />plans had been regulated for quite some time, giving notice to <br />employers that their involvement with the plans were subject to <br />restrictions. 106 S. Ct. at 1027. "Those who do business in <br />the regulated field cannot object if the legislative scheme is <br />buttressed by subsequent amendments to achieve the legislative <br />end." Id. at 1027, quoting FHA v The Darlington, Inc., 358 U.S. <br />84, 91, 79 S. Ct. 141 (1958). Depending upon how long a park <br />owner has been in the business, and how long relative to that <br />time manufactured home parks have been regulated, it may be <br />argued that a park owner either had notice or did not have notice <br />that the field was -regulated and -could be subject -to-further <br />regulations. Analysis of this factor also depends upon the <br />actual investment -backed expectations held by a park owner when <br />purchasing the property or entering the field of park operation. <br />D. Conclusion. <br />Analysis of these three factors demonstrates the extensively <br />ad hoc nature of regulatory taking analysis. The above -cited <br />cases indicate that it is generally difficult for a property <br />owner to prove that a regulatory taking has occurred. This may <br />be particularly true as to the regulation of housing conditions, <br />regarding which the United States Supreme Court has cautioned <br />that "States have broad power to regulate housing conditions in <br />general and the landlord -tenant relationship in particular <br />without paying compensation for all economic injuries that such <br />regulation entails." Loretto v.-Teleprompter Manhattan CATV <br />Corp., 458 U.S. 419, 440, 102 S. Ct. 3164 (1982); See also <br />