Footnotes

E.g. , Transwestern Pipeline Co. v. O’Brien , 418 F.2d 15, 21 (5th Cir. 1969); see United States v. 33.92356 Acres of Land (Piza-Blondet ), 585 F.3d 1, 4,

United States ex rel. Tenn. Valley Auth. v. Indian Creek Marble Co. , 40 F. Supp. 811, 821 (E.D. Tenn. 1941), cited with approval in United States v.

Cf. Olson v. United States , 292 U.S. 246, 256-57 (1934); Miss. & Rum River Boom Co. v. Patterson , 98 U.S. 403, 408-10 (1878). These Standards do not prohibit consideration of customary going rates in federal disposals of easement interests. See Section 4.6.5.1.3.

Transwestern Pipeline , 418 F.2d at 18.

United States ex rel. Tenn. Valley Auth. v. Russell , 87 F. Supp. 386, 389 (E.D. Tenn. 1948).

See Kimball Laundry Co. v. United States , 338 U.S. 1, 7 (1949) (“[T]he proper measure of compensation [in a temporary taking] is the rental that probably could have been obtained ”); Section 4.7; cf. United States v. 883.89 Acres of Land in Sebastian Cty. , 442 F.2d 262, 265 (8th

United States v. Causby , 328 U.S. 256, 268 (1946) (“Since . . . it is not clear whether the easement taken is a permanent or a temporary one, it would be premature for us to consider whether the amount of the award . . . was proper.”).

Va. Elec. , 365 U.S. at 630; see 68.94 Acres , 918 F.2d at 393 n.3; 38.60 Acres , 625 F.2d at 198 & n.1; Transwestern Pipeline , 418 F.2d at 21.

Transwestern Pipeline , 418 F.2d at 18; see also United States v. 10.48 Acres of Land , 621 F.2d 338, 339 (9th Cir. 1980) (prices paid by entity with condemnation authority to acquire easements “are in the nature of compromise to avoid the expense and uncertainty of litigation and are not fair indications of market value”).

Transwestern Pipeline Co. v. O’Brien , 418 F.2d 15, 21 (5th Cir. 1969) (emphasis added); Grizzard , 219 U.S. at 185-86.