Government has the power, with due process of law, to take a person's private property, upon payment of just compensation, and turn it to a public use. The Supreme Court's interpretations of cases involving government's use of its police power or power of eminent domain have been confusing, however, because courts frequently fail to distinguish between the two governmental powers. A method of analysis is presented that attempts to clarify the nature of the government's end in taking the property and the relationship between the end and the means chosen to achieve it. The rules of decision in the analytic method are: (1) an illegitimate end justifies no means; (2) a legitimate end justifies only related means; (3) no end justifies any uncompensated means that will permanently destroy an essential property right; and (4) the end otherwise justifies the means when the public end outweighs the private harm resulting from the means. Taking cases illustrating this method of analysis are discussed in detail, with emphasis on the need for both formal rules and balancing tests. 164 footnotes.