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when Curry was decided did not 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 <br />discussed in Curry 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." Curry, <br />285 Minn. at 388-89, 396, 173 N.W.2d at 411, 415. The standard we applied in Curry is <br />more rigorous than the "reasonable manner" standard adopted in Rowell, and appears <br />consistent with the plain language of the first part 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" standard. 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 />Park Community Council, Inc. v. McDonough, 297 Minn. 285, 289-90, 210 N.W.2d 416, <br />419 (1973), overruled on other grounds 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 Merriam Park was decided did not contain the definition of <br />"undue hardship" that is in the current version of the statute. See 297 Minn. at 289-90, <br />210 N. W.2d at 418-19 (quoting statute). <br />14 <br />