Footnote 1189

1189 See Sections 1.11 and 4.12.1190 For example, in 1878, the Supreme Court described a condemnation involving the “appointment of commissioners to . . . secure a fair appraisement of [a property’s] value” followed by a court determination “as to the amount of compensation the owner of the land was entitled to receive[.]” Miss. & Rum River Boom Co. v. Patterson, 98 U.S. 403, 404-405 (1878). Similarly, in 1893 the Court noted that “[v]iewers were appointed, who reported the value . . . . [and then] the matter was tried before the court . . . as to the question of amount of compensation.” Monongahela Nav. Co. v. United States, 148 U.S. 312, 314 (1893); cf. James H. Boykin, Real Property Appraisal in the American Colonial Era, TheApprAisAl