Wammco, Inc. v. Commonwealth Transportation Commissioner

*134In this appeal from a judgment in a highway condemnation proceeding, we decide whether the trial court properly excluded evidence of adjustment costs as an element of damage to the residue of the property.

I. Proceedings

The Commonwealth Transportation Commissioner (the Commissioner) made a bona fide, but ineffectual, effort to purchase a 17.65-acre tract of land in the City of Chesapeake for construction of a portion of Interstate Highway 664 (1-664). This tract was a part of a larger tract containing 314 acres.

In 1989, the Commissioner recorded a certificate of take pursuant to Code §…