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6.4. HANDOUTS 08-16-2010
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6.4. HANDOUTS 08-16-2010
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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 to "undue hardship" 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. Stat. <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 />court orders the permit to be issued." Stadsvold, 754 N.W.2d at 332; see also In re <br />Livingood, 594 N.W.2d 889, 895 (Minn. 1999). But there is an exception to this general <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 />Earthburners, Inc. v. County of Carlton, where it was unclear whether the zoning <br />authority had applied the relevant statutory provisions, we remanded to the zoning <br />authority for "renewed consideration" under the appropriate standard. 513 N.W.2d 460, <br />463 (Minn. 1994). <br />21 <br />
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