320 Acres, 605 F.2d at 782; United States v. 428.02 Acres of Land, 687 F.2d 266, 269 (8th Cir. 1982); see Cors, 337 U.S. at 332 (“Any increase in value due to [the government’s planned project] in fairness should be excluded from the determination of what compensation would be just.”); cf. United States v. 480.00 Acres of Land (Fornatora), 557 F.3d 1297, 1311 (11th Cir. 2009) (“Courts have only applied exceptions to a general takings doctrine when it is necessary to do so in order to protect the rights of both the taking body and the landowner.”).