Indian Creek Marble Co., 40 F. Supp. at 818-19 (“the inevitable result would be that the land owner would twice receive incidental damages, either in cash compensation or partly in cash and partly in incidental benefits”); see, e.g., eATon, supra note 16 at 32-33 (noting a “chronic and dangerous problem—double damage, i.e., the duplication of just compensation” and illustrating “how easy it is to double damage using the taking plus damages (state) rule”).