United States v. 4.85 Acres of Land, et al., 546 F.3d 613 (9th Cir. 2008)

(during trial involving condemnation action, defendant sought to introduce evidence of three sales at nearby subdivisions which occurred after the taking at issue; trial court refused to allow the evidence and appellate court reversed - trial court erred in making per se evidentiary ruling excluding all post-taking sales).