1172 Bos. Chamber of Commerce v. City of Boston, 217 U.S. 189, 195 (1910); see Brown, 263 U.S. at 83 (“A method of compensation by substitution would seem to be the best means of making the parties whole” in “peculiar” circumstances presented.); see also Duncanville, 469 U.S. at 37 (O’Connor, J., concurring) (“the make-whole remedy intended by the Just Compensation Clause”); Lutheran Synod, 441 U.S. at 511 (“compensation required to make the owner whole”), 516 (“The guiding principle of just compensation . . . is that the owner of the condemned property ‘must be made whole but is not entitled to more.’” (quoting Olson v. United States, 292 U.S. 246, 255)).acquisition, not the nature of the acquisition itself. Regardless of the form of compensation, the Fifth Amendment does not require any award for non-compensable (or “consequential”) damages, further discussed in Section 4.6. 1173