Footnotes

883.89 Acres in Sebastian , 442 F.2d at 265. Note that the term sale refers to a transaction involving the property interest at issue – here, a leasehold. Id.

See United States v. Bedford Assocs. , 548 F. Supp. 732, 743-45 (S.D.N.Y. 1982) (considering whether property should be valued in ‘as is’ condition or whether determination of market rental price should include renovations), modified in other respects, 713 F.2d 895 (2d Cir. 1983); United States v. Flood Bldg. , 157 F. Supp. 438, 442-44 (N.D. Cal. 1957) (tenant alterations “did not wreak havoc and destruction to the interior” but rather made space “suitable for occupation by commercial type tenants, and owing to the excellent location of the building . . . its continuing utility can readily be perceived”).

765.56 Acres I , 164 F. Supp. at 948.

United States v. 79.20 Acres of Land in Stoddard Cty. , 710 F.2d 1352, 1355 (8th Cir. 1983).

E.g. , 3.6 Acres , 395 F. Supp. 2d at 992 (finding $1.00 was just compensation for acquisition of easement that did not exceed preexisting easement).

Bos. Chamber of Commerce v. City of Boston , 217 U.S. 189, 195 (1910); 79.20 Acres in Stoddard , 710 F.2d at 1354-55.

See, e.g. , United States v. 3.6 Acres of Land in Spokane Cty ., 395 F. Supp. 2d 982 (E.D. Wash. 2004); 765.56 Acres I , 164 F. Supp. at 945-47.

United States v. 564.54 Acres of Land (Lutheran Synod), 441 U.S. 506, 516 (1979) (quoting Olson v. United States, 292 U.S. 246, 255 (1934)); see Gettysburg Tower, 409 F.3d at 145-46 & nn.11-12.

United States v. Grizzard, 219 U.S. 180, 184-85 (1911); United States v. 57.09 Acres of Land in Skamania Cty. (Peterson I), 706 F.2d 280, 281 (9th Cir. 1983).

See Section 4.2.2 (The Unit Rule); Grizzard , 219 U.S. at 184-85 (“[J]ustice . . . required that regard be had to the effect of the appropriation of a part of a single parcel upon the remaining interest of the owner, by taking into account both the benefits which accrue and the depreciation which results to the remainder in its use and value.”); Bos. Chamber , 217 U.S. at 194-95 (The government cannot “be made