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6.4. HANDOUTS 08-16-2010
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6.4. HANDOUTS 08-16-2010
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A. <br />Krummenacher argues that the City's decision was arbitrary and capricious <br />because the City did not apply the proper standard to determine whether Liebeler <br />demonstrated "undue hardship" as defined in Minn. Stat. § 462.357, subd. 6. This <br />provision allows a city to grant a variance "from the literal provisions of the ordinance in <br />instances where their strict enforcement would cause undue hardship because of <br />circumstances unique to the individual property under consideration." Minn. Stat. <br />§ 462.357, subd. 6. <br />Minnesota Statutes § 462.357, subd. 6, provides a definition of "undue hardship," <br />and that definition requires that three factors be met. Specifically, the statute defines <br />"undue hardship" as meaning, <br />the property in question cannot be put to reasonable use if used under conditions <br />allowed by the official controls, the plight of the landowner is due to <br />circumstances unique to the property not created by the landowner, and the <br />variance, if granted, will not alter the essential character of the locality. <br />Id.6 To receive a variance, the applicant must show that he or she meets all of the three <br />statutory requirements of the "undue hardship" test. Id. In addition to satisfying the <br />"undue hardship" requirement, the statute allows municipalities to grant variances only <br />6 The Minnetonka City Code has almost identical provisions. Minnetonka City <br />Code § 300.07.1(a) ("A variance may be granted from the literal provisions of this <br />ordinance in instances where strict enforcement would cause undue hardship because of <br />circumstances unique to the individual property under consideration and when it is <br />demonstrated that such actions would be consistent with the spirit and intent of this <br />ordinance. Undue hardship means the property in question cannot be put to a reasonable <br />use if used under conditions allowed by this ordinance, the plight of the landowner is due <br />to circumstances unique to the property not created by the landowner, and the variance, if <br />granted, would not alter the essential character of the neighborhood."). <br />11 <br />
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