Footnote 1136

1136 Jefferson Cty. v. Tenn. Valley Auth., 146 F.2d 564, 566 (6th Cir. 1945); see Naval Shipyard, 395 F.2d at 268 (“The State has lost the profit potential, if any, which these lands may have had as part of the ‘channel.’ On the other hand, the untaken lands have been relieved of the burdens of the dedication. These and other relevant factors must be considered . . . to determine whether the taking resulted in a decrease in the value of the untaken portion of the channel ”).1137 See United States v. 50 Acres of Land (Duncanville), 469 U.S. 24, 30 (1984) (“basic principles of indemnity embodied in the Just Compensation Clause”); United States v. 564.54 Acres of Land (Lutheran Synod), 441 U.S. 506, 517 (1979) (“‘basic equitable principles of fairness’ underlying the Just Compensation Clause” (quoting United States v. Fuller, 409 U.S. 488, 490 (1973))); cf. United States v. 46,672.96 Acres of Land in Doña Ana Ctys., 521 F.2d 13, 17 (10th Cir. 1975) (“The fact that [property] has very little value cannot justify . . . using an inapplicable measure ”).