d) Flights of aircraft over private land which are so low and frequent as to be a direct and immediate interference with the enjoyment and use of the land are as much an appropriation of the use of the land as a more conventional entry upon it. Pp. 328 U. S. 261-262, 328 U. S. 264-267.
That sounds a bit different then airspace. Planes can disrupt ones enjoyment, but I fail to see how crossing from public to public causes the landowner loss of enjoyment.
