There is an interesting opinion given by the court in a Florida rails-to-trails condemnation taking matter in which the court considered competing qualitative and quantitative adjustment methodologies as one of the issues --
Childers v. United States. Here is a brief part of the court's discussion:
Quantitative Versus Qualitative Comparable Sales Analysis
. . . Mr. Durrance testified as to why he used the qualitative approach:
If I have a reason for a percentage adjustment or some kind of basis for it, sure, you can do that. But again, real quickly, what an appraiser — what I'm trying to do is to mimic the market, how would the market react. And the market does not walk around with a clipboard and a summary chart like this and put minus 15 plus 20 is how this property stacks up to this property. They look at all the available comparable properties, and what it is they want to buy or sell, and say, how does this property stack up to the others. Tr. 455.
Dr. Kilpatrick, Plaintiffs' expert in appraisal practice standards and methodology, opined that the qualitative approach was superior here because Plaintiffs' properties were large tracts with "multiple interlocking complex attributes, and it would be overly judgmental of an appraiser to try to separate those attributes out and give a marginal value to each one of them." Tr. 669-70.
[10] Dr. Kilpatrick further testified that quantitative comparable sales analyses are appropriate for appraising detached single-family properties. Tr. 670.
The Court concludes that for the most part Mr. Durrance's qualitative analysis was more persuasive, because he provided a more compelling analysis regarding how the pertinent features of a property would affect the price a buyer was willing to pay.
[11] Plaintiffs' expert better assessed features a knowledgeable buyer would consider, such as allowable density, the presence of environmental lands, and the impact of easements or encumbrances. Mr. Durrance also better accounted for market conditions by using the contract date, rather than the closing date of a given property sale. In contrast, Mr. Underwood's quantitative approach did not as thoroughly address important considerations such as development restrictions, particular land use restrictions, and features that impose additional costs, and he used only the closing date for most sales. Additionally, the experts appraised Plaintiffs' properties as vacant, with residential and/or mixed-use development as the highest and best use. As Dr. Kilpatrick testified, the qualitative approach is preferred for vacant properties while a quantitative approach is better for detached single-family properties. Tr. 669-70.
(The full case is here:
Childers Opinion (2014))
