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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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language of the statute to hold that a municipality does not have the authority to grant a ! <br /> variance unless the applicant can show that her property cannot be put to a reasonable use <br /> without the variance. <br /> Based on the plain language of the statute, and our precedent interpreting language <br /> similar t� "undue ha.�dship" in the context of a local government's authority to grant <br /> variances, we reject the "reasonable manner" standard from Rowell. We hold that the <br /> City inaccurately applied the first factor in the "undue hardship" definition of Minn. Sta.t. <br /> § 462.357, subd. 6. Our resolution of this issue makes it unnecessary for us to resolve <br /> the other issues Krummenacher raises on appeal. <br /> B. ' <br /> Having concluded that the City applied the law incorrectly, we must address the <br /> remedy. In cases where a variance has been denied, the general rule is that "[i)f the <br /> zoning authority's decision is arbitrary and capricious, the standard remedy is that the <br /> � <br /> court orders the permit to be issued." Stadsvold, 754 N.W.2d at 332; see also In ��e �'� <br /> � <br /> Livingood, 594 N.W.2d 889, 895 (Minn. 1999). But there is an exception to this general j <br /> rule "when the zoning authority's decision is premature and not necessarily arbitrary." <br /> Stadsvold, 752 N.W.2d at 333 (internal quotation omitted). For example, in <br /> EaT•thbuT-nei�s, Inc. v. County of Carlton, where it was unclear whether the zoning <br /> i <br /> authority had applied the relevant statutory provisions, we remanded to the zoning <br /> authority for "renewed consideration" under the appropriate standard. 513 N.W2d 460, <br /> 463 (Minn. 1994). <br /> 21 <br />
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