Footnote 874
Compare United States v. 3,218.9 Acres of Land in Warren Cty. , 619 F.2d 288, 289-91 (3d Cir. 1980) (noting “explicit” description of “the nature of the estate to be taken” and “clear” language that “third party mineral rights are not intended to be affected”), with United States v. City of Tacoma , 330 F.2d 153, 155-56 (9th Cir. 1964) (reversing judgment of compensation that did not resolve “the nature of the easement taken,” as leaving “this critical issue undecided” was detrimental to both the United States and the landowner).