Whether parties owning property inside national forest boundaries must exhaust special use permitting requirements before bringing a takings claim when those requirements implicitly deny private easement claims

QUESTION(S) PRESENTED Whether parties who own property inside national forest boundaries or other federally-owned lands, and who assert R.S. 2477 rights to easements accessing their inheld estates, must exhaust federally-mandated special use permitting requirements to rebuild roads damaged by forest fires before bringing a taking’s claim when those permitting requirements implicitly deny claims of private ownership in the easements and place undue burdens on private property ownership? Whether the United States has physically occupied property when it denies the existence of private easements across federal lands pursuant to R.S. 2477 and seeks to prevent the putative owners of those easements from repairing roads or generally exercising any ownership rights over those easements without the permission of the federal government?