DETERMINATION OF THE VALUE OF REAL ESTATE 205
The owner who is forced to part with his property in such cases
should obtain a reasonable reward for his foresight in acquiring
property of special adaptability to some important use. This
reward should, whenever practicable, bear some reasonable relation
 to the value for other uses to which the property can be
put. There may be cases in which a 2 5 or 50 per cent allowance
will be adequate, and there may be others in which this allowance
may exceed the value for other uses two-, five- or even ten-fold,
and there may also be occasional cases where a reasonable allowance
 not capable of demonstration, but yet fair when all circumstances
 are considered may be out of all relation to value
for other uses.
The value multiple, as applied in any locality to railroad
rights of way, and the unit price per pole of a power line are the
outcome of numerous adjustments resulting from a regard to
considerations as above set forth, and where such multiples are
recognized, they, in turn, as already stated, have an effect upon
market value of other similar easements.
The Value Multiple in the Minnesota Rate-Cases. — In connection
 with the valuation of rights of way and other lands as a
part of the appraisal to be taken into account when the rates of
public utilities are to be fixed, the decision of the United States
Supreme Court in the Minnesota Rate-Cases is of interest
(230 U. S. 352; 33 Sup. Ct. 729, June 9, 1913). Justice Hughes,
in writing the decision of the court, says:
“ The increase sought for ° railway value’ in these cases is
an increment over all outlays of the carrier and over the values
of similar land in the vicinity. It is an increment which can
not be referred to any known criterion, but must rest on a mere
expression of judgment which finds no proper test or standard
in the transactions of the business world. It is an increment
which in the last analysis must rest on an estimate of the value
of the railroad use as compared with other business uses, it
involves an appreciation of the return from rates (when rates
themselves are in dispute) and a sweeping generalization embracing
 substantially all the activities of the community. For
an allowance of this character there is no warrant.