In what circumstances will the courts rely on the special benefit rule to determine just compensation?

In such circumstances, the role of the courts is not to search for a deceptive precision by abstracting the definition of "benefit" to the point where it becomes unnecessary to distinguish between special and general benefits. To do so would sacrifice the additional measure of fairness provided by the special benefit rule's more individualized determination of the injury inflicted by a taking. It is both futile and misleading to attempt "to reduce the concept of 'just compensation' to a formula." (United States v. Cors (1949) 337 U.S. 325, 332, 69 S.Ct. 1086, 1090, 93 L.Ed. 1392.) Instead, courts must engage in a search for "practical standards" and "endeavor to find working rules that will do substantial justice." (Ibid.) However fact-bound and imprecise these rules may seem, their legitimacy should turn on their effectiveness in practice, not on their theoretical elegance. Of necessity, given the inherent uniqueness of every parcel of land and the individuality of its relationship to any particular project, the determination of what constitutes a special benefit will be a fact-intensive inquiry in which generalizations will be of only limited utility. The special benefit rule, while it does not turn every determination of whether a particular type of benefit counts as an offset into a rule of law that does not vary with the surrounding circumstances, has proven itself a workable rule that produces substantial justice.