Rule 71.1 (formerly Rule 71A) ended the use of state procedures in federal condemnations in 1951, establishing “a uniform set of procedures governing federal condemnation actions.” Kirby Forest Indus., Inc. v. United States, 467 U.S. 1, 3-4 & n.2 (1984) (discussing Rule 71A); F ed. R. ciV. P. 71.1. However, condemnations by pipeline companies under the Natural Gas Act are governed by state law in some circuits. E.g., Rockies Express Pipeline LLC v. 4.895 Acres of Land, 734 F.3d 424, 429-30 (6th Cir. 2013); but see, e.g., S. Nat. Gas Co. v. Land, Cullman Cty., 197 F.3d 1368 (11th Cir. 1999) (applying federal procedural law); see also Portland Nat. Gas Transmission Sys. v. 19.2 Acres of Land, 318 F.3d 279, 282 n.1 (1st Cir. 2003) (“Perhaps surprisingly, several circuits [apply] state substantive law as well as formal practice [in Natural Gas Act condemnations].”). Cases decided on state law grounds are not applicable to federal acquisitions, in which compensation must be determined under federal law. United States v. Miller, 317 U.S. 369, 379-80 (1943).