See Miller , 317 U.S. at 376; 8.41 Acres in Orange , 680 F.2d at 393 & n.6; Cole Inv. Co. v. United States , 258 F.2d 203, 205 (9th Cir. 1958) (“The test in severance damage cases [is] that market value is the criterion for severance damages and that ‘strict proof of the loss in market value to the remaining parcel is obligatory.’” (quoting Honolulu Plantation , 182 F.2d at 179)); United States v. Certain Parcel of Land in Jackson Cty. , 322 F. Supp. 841, 850 (W.D. Mo. 1971) (“‘Adaptability to a common use, or an intention on the part of the owner to put the property to