Piza-Blondet, 585 F.3d at 9 n.6 (citing 4A nichols, ThelAw oFeminenTdomAin § 14.02[4] (rev. 3d ed. 1981)); United States v. 760.807 Acres of Land in Honolulu, 731 F.2d 1443, 1445 (9th Cir. 1984) (“Using [the before and after] method, any diminution in value of the remainder resulting from the taking and use of part of the original parcel, sometimes termed ‘severance damages,’ would be included in the award.”); cf. United States v. 901.89 Acres of Land in Davidson & Rutherford Ctys. (Davenport), 436 F.2d 395, 399 (6th Cir. 1970) (reversing lower court’s rejection of before and after valuation that reflected direct and special benefits to remainder after taking); United States v. Werner, 36 F.3d 1095, 1994 WL 507461, at *5 (4th Cir. 1994) (unpubl.) (“‘[T]he taking may not affect the value of the remainder in any way [or] it may either damage or benefit the remainder In any such situation the measure of just compensation is the same, that is, the difference