United States v. 403.14 Acres of Land in St. Clair Cty., 553 F.2d 565, 567 n.2 (8th Cir. 1977); accord United States v. 6.24 Acres of Land (Weber), 99 F.3d 1140, 1996 WL 607162, at *4 (6th Cir. 1996) (per curiam) (unpubl.); United States v. 2.33 Acres of Land in Wake Cty., 704 F.2d 728, 730 (4th Cir. 1983); see United States v. 33.92356 Acres of Land (Piza-Blondet), 585 F.3d 1, 9 (1st Cir. 2009) (“The before and after method is particularly advantageous where either it is difficult to value fairly the condemned tract as a separate parcel or one of the parties contends that the remainder was harmed or benefitted by the condemnation.”).