The appropriateness of such a standard, in one form or another, has been considered by other state courts in other contexts. Some have adopted it, see, e.g, Barnes v. North Carolina State Highway Commission, 250 N.C. 378, 109 S.E.2d 219 (1959) (there must be "substantial unity of ownership" to collect severance damages in an eminent domain proceeding), but the majority have not. See, e.g., Stockton v. Ellingwood, 96 Cal.App. 708, 275 P. 228 (1929) (unity of ownership is required for allowance of severance of damages); Coatsworth v. Lehigh Valley R. Co., 73 Misc. 645, 131 N.Y.S. 300 (1911) (there must be identical ownership to recover severance damages). Illustrative of the majority view is Weldon v. State, 495 So.2d 1113 (1985).
"Textbook authorities and the decisions dealing with the question indicate that as a general proposition, ordinarily actual contiguity or physical connection of tracts is essential in order to create a `unit' as a basis for awarding damages where a part or all of only one of the tracts is taken — but it is not necessarily a conclusive test." (See, also, Stevens v. New York El. R.R. Co., 130 N.Y. 95, affg. 25 Jones Sp. 416; Bischoff v. New York El. R.R. Co., 138 N.Y. 257; Coatsworth v. Lehigh Val. R.R. Co., 73 Misc. 645. ) The same text at page 725 refers to the English law on the subject.