Case Note, The Eighth Circuit Declares New Law for Owners of Land Encumbered by FWS Easements: Drain Those After-Expanded Wetlands, but Ask Nicely First (United States v. Johansen, 93 F.3d 459, 8th Cir. 1996,) 4 MISSOURI ENVIRONMENTAL L. & POLICY REV. 158-169 (1997).