rth an individual places on particular property at a given time."25 Permitting such subjective considerations to determine what constitutes just compensation "would enhance the risk of error and prejudice."26 The Court has held that the market-value standard is not constitutionally mandated and thus might not require strict adherence.27 Indeed, the Court has long recognized that market value fails to give "full and literal force" to the principle of putting property owners in as good a position as if their property had not been taken. In particular, the Court has frequently observed that just compensation does not necessarily require compensation for the special value that a piece of property may have for a particular user.28 Furthermore, the Court does not allow recovery of any transaction costs imposed by the taking. As a result, the market-value standard has been criticized for failing to make whole those whose property is taken. 30 The Court has nonetheless concluded that the market-value standard offers an appropriate accommodation for the exigencies of modern governance. In most cases market value "achieves a fair 'balance between the public's need and the claimant's loss,""31 thereby mediating "the conflict between the people's interest in public projects and the principle of indemnity to the landowner."32 Although a failure to consider subjective valuation can impose real costs on those whose property is taken, this loss is "properly treated as part of the burden of common citizenship."3 As a result, any exceptions to the market-value rule remain very narrow. 24 Kirby Forest, 467 U.S. at 10 n. 15. 25 Lutheran Synod, 441 U.S. at 511. See also United States ex rel. Tenn. Valley Auth. V. Powelson, 319 U.S. 266, 280 (1943). 26 Duncanville Landfill, 469 U.S. at 36. 27 Toronto, Hamilton & Buffalo, 338 U.S. at 402; United States V. Fuller, 409 U.S. 488, 490 (1973); Lutheran Synod, 441 U.S. at 512; Kirby Forest, 467 U.S. at 10 n. 14; Duncanville Landfill, 469 U.S. at 30-31; see also United States V. Cors, 337 U.S