Footnote 728
United States ex rel. Tenn. Valley Auth. v. Indian Creek Marble Co. , 40 F. Supp. 811, 820 (E.D. Tenn. 1941), cited with approval by City of Van Buren v. United States , 697 F.2d 1058, 1062 (Fed. Cir. 1983), and United States v. 2,847.58 Acres of Land in Bath Ctys. , 529 F.2d 682, 686 (6th Cir. 1976); see United States v. 760.807 Acres of Land in Honolulu , 731 F.2d 1443, 1445 (9th Cir. 1984) (“Using [the before and after] method, any diminution in value of the remainder resulting from the taking and use of part of the original parcel, sometimes termed ‘severance damages,’ would be included in the award.”).