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when Cu���y was decided did n�t contain the definition of"undue hardship" that is in the <br /> current version of the statute. See Minn. Stat. § 462.357 (1969). Moreover, while we I <br /> discussed in Cur�y the dimensions of a structure that could theoretically be built to <br /> comply with the statutory requirements, we based our determination that the variance was <br /> properly granted on the municipality's ordinance. That ordinance required a showing of <br /> "particular hardship," and we concluded that the standard was met because the <br /> "plaintiffs' lot, in the absence of a variance, would be unusable for any purpose." Cur�y, � <br /> � <br /> 285 Minn. at 388-89, 396, 173 N.W.2d at 411, 415. The standard we applied in CuYry is <br /> znore rigorous than the "reasonable manner" standard adopted in Rowell, and appears <br /> consistent with the plain language of the first paz-t of the "undue hardship" definition that <br /> is in the current statute. See Minn. Stat. § 462.357, subd. 6. <br /> In addition, in formulating the "reasonable manner" standard, the court in Rowell <br /> appears to have relied on the "practical difficulties" standard.� See Rowell, 446 N.W.2d <br /> at 922. But we have made a clear distinction between the "practical difficulties" standard <br /> and the "undue hardship" standa�d. See Stadsvold, 754 N.W.2d at 328-31. As we <br /> explained in Stadsvold, the "practical difficulties" standard applies to review of county <br /> decisions to grant area variances, while the "undue hardship" standard applies to all <br /> � In support of the application of this standard, the court of appeals cited Merriam <br /> Pa�•k Cona�nunity Council, Inc. v. McDonough, 297 Minn. 285, 284-90, 210 N.W.2d 416, <br /> 419 (1973), overruled on othe�• gi°ounds by Northwestern College v. City of Arden Hills, <br /> 281 N.W.2d 865, 868 n.4 (Minn. 1979). As in Curry, the version of Minn. Stat. <br /> § 462.357 in effect when Me»•iam Park was decided did n�t contain the definition of <br /> "undue hardship" that is in the cunent version of the statute. See 297 Minn. at 289-90, <br /> 210 N.W.2d at 418-19 (quoting statute). <br /> 14 <br />