336 the statute provided no no tice to owners of

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336 The statute provided no no- tice to owners of interests, however, save for its own publication; nor did it require surface owners to notify owners of mineral inter- ests that the interests were about to expire. 337 By a narrow mar- gin, the Court sustained the statute, holding that the state’s inter- est in encouraging production, securing timely notices of property ownership, and settling property titles provided a basis for enact- 333 Connecticut Ins. Co. v. Moore, 333 U.S. 541 (1948). Justices Jackson and Doug- las dissented on the ground that New York was attempting to escheat unclaimed funds not actually or constructively located in New York, and which were the prop- erty of beneficiaries who may never have been citizens or residents of New York. 334 341 U.S. 428 (1951). 335 454 U.S. 516 (1982). 336 With respect to interests existing at the time of enactment, the statute pro- vided a two-year grace period in which owners of mineral interests that were then unused and subject to lapse could preserve those interests by filing a claim in the recorder’s office. 337 The act provided a grace period and specified several actions which were suf- ficient to avoid extinguishment. With respect to interests existing at the time of en- actment, the statute provided a two-year grace period in which owners of mineral interests that were then unused and subject to lapse could preserve those interests by filing a claim in the recorder’s office. 1900 AMENDMENT 14—RIGHTS GUARANTEED
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ment, and finding that due process did not require any actual no- tice to holders of unused mineral interests. 338 The state “may im- pose on an owner of a mineral interest the burden of using that interest or filing a current statement of interests” and it may simi- larly “impose on him the lesser burden of keeping informed of the use or nonuse of his own property.” 339 Health, Safety, and Morals Health. —Even under the narrowest concept of the police power as limited by substantive due process, it was generally conceded that states could exercise the power to protect the public health, safety, and morals. 340 For instance, an ordinance for incineration of gar- bage and refuse at a designated place as a means of protecting pub- lic health is not a taking of private property without just compen- sation, even though such garbage and refuse may have some elements of value for certain purposes. 341 Or, compelling property owners to connect with a publicly maintained system of sewers and enforcing that duty by criminal penalties does not violate the Due Process Clause. 342 There are few constitutional restrictions on the extensive state regulations on the production and distribution of food and drugs. 343 Statutes forbidding or regulating the manufacture of oleomarga- rine have been upheld, 344 as have statutes ordering the destruction of unsafe food 345 or confiscation of impure milk, 346 notwithstanding that, in the latter cases, such articles had a value for purposes other than food. There also can be no question of the authority of the
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