It has been two years since the Supreme Court's ruling against private property owners in the Kilo Case in New London, Connecticut. Since the Supreme Court’s ruling, several states have passed eminent domain reform. The Castle Coalition, a nationwide property rights advocacy group associated with the Institute of Justice, graded states on progress toward eminent domain reform. States where it is now impossible or extremely difficult for government to take private property for another individual's private gain got high marks and those where it is easy got low marks. States that failed to pass any eminent domain reform received a failing grade. Missouri received a grade of "D".
Missouri’s House Bill 1944, effective in August of 2006, did specify that property cannot be condemned "solely" for economic development and ends the prior practice of letting private developers initiate condemnations on their own behalf. However, the Bill allows government agencies to take private property for the use of other private parties for any other justification. Although House Bill 1944 exempts farm land from being declared blighted, it "continues to let cities condemn whole neighborhoods as 'blighted' based on vague, subjective factors,". Such factors include "inadequate street layout," "unsafe conditions" and "obsolete platting." Any Missouri community, no matter how well maintained, could be at risk.