Footnote 372

United States v. Miller, 317 U.S. 369, 376 (1943) (“loosely”); United States v. 9.20 Acres of Land in Polk Cty., 638 F.2d 1123, 1125 n.2 & 1127 (8th Cir. 1981) (discussing “misleading” nature of term and concept of ‘severance damages’); United States v. 91.90 Acres of Land in Monroe Cty. (Cannon Dam), 586 F.2d 79, 86 (8th Cir. 1978) (“[W]hile the solution to the problem [of measuring compensation in partial takings] is simple, it seems to be frequently missed. And, the difficulty seems to arise out of the concept of ‘severance damage.’”); Honolulu Plantation, 182 F.2d at 175 n.1 (“The use of this term is to be criticized because it is apt to lead to loose thinking.”).