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5.4. SR 05-17-2010
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5.4. SR 05-17-2010
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owner had no vested right in zoning. ." Property <br />Research, 467 N.W.2d at 643. <br />C. As the Minnesota Court of Appeals recognized in Concept Properties, <br />LLP v. City of Minnetrista, 694 N.W.2d 804, 820 (Minn. Ct. App. <br />2005), "[t]he purchase of property or acquisition of a building permit <br />fails to create a vested right in development. [citation omitted]. <br />Likewise, neither a municipality's preliminary approval of a project <br />nor a determination that a development plan would be consistent with <br />applicable land-use regulations will create a vested right. [citation <br />omitted.] And most notably, payment of an assessment for <br />construction of a sewer system does not create a vested right in a land <br />use that contravenes municipal land-use regulations. [citation <br />omitted]." There, the Court of Appeals rejected a claim that a sewer <br />assessment gave the property owner a vested right to have its property <br />included in the MUSA and connected to the sewer system, reasoning <br />that "the sewer assessment created, at most, an expectation that the <br />property owner would be able to connect to the sewer and develop the <br />property in the next IO to 20 years. An expectation to develop the <br />property does not create a vested right to do so." Id. <br />D. So when will a vested right to a continuation of the existing zoning <br />arise? <br />1. "[T]he doctrine of vested rights exists to protect developers <br />from changes in zoning laws aimed at frustrating development." <br />Yeh v. County of Cass, 69b N.W.2d 115, 132 (Minn. Ct. App. <br />2005). "In avested-rights analysis, courts ask whether a <br />developer has progressed sufficiently with construction or <br />otherwise to acquire a vested right in completing the project <br />under the prior Land-use regulations.' Halla Nursery v. City o <br />Chanhassen, 763 N.W. 2d 42, 4$-49 (Minn. Ct. App. 2009), <br />rev. granted, decision pending. Nevertheless, there are very <br />limited circumstances in which Minnesota courts will recognize <br />that a right has "vested" in a manner that truly protects <br />developers from changes in zoning laws aimed at frustrating <br />development. <br />2. When a permit is granted and substantial construction <br />follows: Minnesota will recognize a vested right to be free <br />from more stringent land use regulations only after the property <br />3 <br />
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