4.6.2.1. Compensable (Severance) Damages.In the context of the Fifth Amendment, damage is simply “the equivalent for the injury done,” just as compensation, “standing by itself, carries the idea of an equivalent.”749 Yet the concept of compensable damage is often misunderstood, as the Eighth Circuit explained: 

It is incorrect to think of “severance damages” as a separate and distinct item of just compensation apart from the difference between the market value of the entire tract immediately before the taking and the market value of the remainder immediately after the taking. In the case of a partial taking, if the “before and after” measure of compensation is properly [applied], there is no occasion . . . to talk about “severance damages” as such, and indeed it may be confusing to do so. The matter is taken care of automatically in the “before and after” submission.750

Compensable damages may reflect a decrease in the market value of the remainder arising from (1) the government’s planned use of the part acquired, and/or (2) the relation of the part acquired to the larger parcel.751 156