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07-13-2010 Council Work Session Packet
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07-13-2010 Council Work Session Packet
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; <br /> � <br /> determined that the expansion of the garage was a reasonable use of the properly and that <br /> the request met the other requirements of the sta.tute. Specifically, as reflected in the City <br /> Council Resolution, the Ciiy found that "the proposal is reasonable" and with respect to I <br /> "undue hardship," that "[t]here is an undue hardship due to the topography of the site, <br /> width of the lot, location of the driveway and existing vegetation." <br /> The plain language of the statute and our precedent compel us to reject the City's <br /> invitation to adopt Rowell's interpretation of"undue hardship." The statute provides that <br /> to prove "undue hardship," the vaziance applicant must show that "the property in <br /> question cannot be put to a reasonable use" without the variance. Minn. Stat. § 462.357, <br /> subd. 6. Notwithstanding this language, the colu-t of appeals concluded that "[t]his <br /> provision does not mean that a property owner must show the land cannot be put to any <br /> reasonable use without the variance." Rowell, 446 N.W.2d at 922. The court of appeals <br /> essentially rewrote the statute to mean that a municipality may grant a variance when the <br /> "properly owner would like to use the property in a reasonable manner that is prohibited <br /> by the ordinance." Id. at 922. Although the Rowell "reasonable manner" standard has <br /> been used for over 20 years, we simply cannot reconcile that standard with the plain <br /> language of the statute. <br /> The IZowell standard is also inconsistent with our precedent. In support of the <br /> application of a "reasonable manner" standard for determining "undue hardship," Rowell <br /> cites Cur�y v. Young, 285 Minn. 387, 173 N.W.2d 410 (1969), for the proposition that a <br /> variance is "required where a setback requirement would force a property owner to build <br /> a much smaller st�ucture." Id. at 922. The version of Minn. Stat. § 462.357 in effect <br /> 13 <br />
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