Which of the following is true according to the first tier of substantive due process claims?

a) The government cannot randomly take the life of a criminal defendant.

b) Legislation on business affairs is subject to minimal judicial scrutiny.

c) The law ensures that the government does not take private property without just compensation.

d) A law will be unconstitutional unless it is specifically geared to serve a significant governmental purpose.

e) The government cannot take private property without just compensation.