How have courts interpreted the meaning of "use" in determining just compensation for the destruction of a home?

This court applied this understanding of "use" in denying compensation for the government-caused destruction of a home in Miller v. City of Palo Alto (1929) 208 Cal. 74, 77, 280 P. 108. In that case, a city's disposal of smoldering incinerator ashes in a vacant lot caused a fire which destroyed the plaintiffs' house. This court held that the plaintiffs were not entitled to compensation under the just compensation clause of the state Constitution because the city's destruction of their house did not put the house to a " 'use by or for the government' " or put it to any " 'utility or advantage.' " (Ibid.)