1163 Brown, 263 U.S. at 81-83; see Duncanville, 469 U.S. at 30-34, 30 n.12; United States v. 564.54 Acres of Land (Lutheran Synod), 441 U.S. 506, 513 (1979); see also Duncanville, 469 U.S. at 37 (O’Connor, J., concurring) (“When a local governmental entity can prove that the market value of its property deviates significantly from the make-whole remedy intended by the Just Compensation Clause and that a substitute facility must be acquired to continue to provide an essential service, limiting compensation to the fair market value in my view would be manifestly unjust.”).