Footnotes

See, e.g. , Ga.-Pac. Corp. v. United States , 640 F.2d 328, 336-37 (1980) (per curiam).

See Section 4.11.1.

United States v. Causby , 328 U.S. 256, 268 (1946); see City of Tacoma , 330 F.2d at 155-56.

United States v. Grizzard , 219 U.S. 180, 184-85 (1911).

Black’s Law Dictionary defines an easement as “[a]n interest in land owned by another person, consisting in the right to use or control the land, or an area above or below it, for a specific limited purpose ” Easement, Black’s Law Dictionary (10th ed. 2014).

Grizzard , 219 U.S. at 184, 185-86.

See Piza-Blondet , 585 F.3d at 9 (refusing alternative valuation method when there was “no persuasive reason why the before and after method would be unfair in assessing the value”); United States v. 12.94 Acres of Land in Solano Cty. , No. CIV. S-07-2172, 2009 WL 4828749, at *5-*6, 2009 U.S. Dist LEXIS 114581, at *15-*21 (E.D. Cal. Dec. 9, 2009) (error to analyze value of the part taken separately from the total); cf.

Indian Creek Marble Co. , 40 F. Supp. at 818.

While the Fourth Circuit previously broke from other federal courts in adopting the taking plus damages method, it subsequently embraced the federal before and after rule, observing “it is well settled that in the event of a ‘partial taking’ the measure of just compensation is the difference

2.33 Acres , 704 F.2d at 729-31. The vacated award valued the larger parcel before the taking at $296,870 and the remainder after the taking at $240,663, a difference of approximately $56,000, yet would have awarded total compensation in excess of $200,000. See id.