See McCoy v. Union Elevated R.R. Co. , 247 U.S. 354, 365 (1918); Harris v. United States , 205 F.2d 765, 767 (10th Cir. 1953) (distinguishing between federal and state constitutional provisions for just compensation); cf. eATon, supra note 16, at 41-42 & nn.26-31 (“most authorities argue that the complexity of the state rule and its potential for double damages are so great that the before and after rule should be adopted”).