ZONING - MINNESOTA

Douglas A. Ruhland, Appellant, v. City of Eden Valley, Respondent.

Court of Appeals of Minnesota - July 1, 2013 - N.W.2d - 2013 WL 3285019

On appeal from the district court’s summary-judgment order confirming city’s decision to rezone certain property from “single and two-family residential” to “commercial reserve,” neighbor who objected to the zoning change argued that the city (1) failed to follow its comprehensive plan; (2) failed to comply with its zoning ordinance; (3) did not make sufficient findings of fact to support its decision and the record does not support the findings that it did make; (4) made a decision that constitutes impermissible spot zoning; and (5) made a decision that was improperly impacted by conflicts of interest.

In conclusion, the court of appeals observed that a city is required to provide reasons for a zoning decision or risk not having its decision sustained. See Honn, 313 N.W.2d at 416 (“The municipal body need not necessarily prepare formal findings of fact, but it must, at a minimum, have the reasons for its decision recorded or reduced to writing and in more than just a conclusory fashion. By failing to do so, it runs the risk of not having its decision sustained.”). “We also observe that the reasons for the city’s decision in this case are minimal and that greater explanation would have been desirable. However, given our deferential standard of review, we are satisfied that the city’s zoning decision was not unreasonable, arbitrary, or capricious. We therefore affirm.”



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