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Northwestern College <br />v. City of Arden Hills,, <br />281 N.W.2d 865 <br />(Minn. 1979) <br />State, by Rochester <br />Assn of <br />Neighborhoods v. City <br />of Rochester, 268 <br />N.W.2d 885 (Minn. <br />1978) <br />See Section VC <br />Standards for <br />reviewing zoning <br />applications: limits on <br />city discretion. <br />Minn. Stat. § 15.99, <br />subd. 2(a) . <br />See Section VA The <br />60 -Day Rule. <br />• Variances. <br />In quasi-judicial situations, a reviewing court will closely scrutinize the <br />city's decision, to determine whether they city has provided a legally and <br />factually sufficient basis for denial of an application. <br />In quasi-judicial situations, due process and equal protection are the main <br />reasons for the more stringent scrutiny. Due process and equal protection <br />under the law demand that similar applicants must be treated uniformly by <br />the city. The best process for insuring similar treatment among applicants is <br />to establish standards in the ordinance and to provide that if standards are <br />met, the zoning permit must be granted. An application may generally only <br />be denied for failure to meet the standards in city ordinances. <br />A reviewing court will overrule a quasi-judicial city zoning decision if it <br />determines that the decision was arbitrary (failed to treat equally situated <br />applicants equally or failed to follow ordinance requirements). <br />1. Standard of review for re- zoning applications <br />An application for a rezoning is a request for an amendment to the zoning <br />ordinance. When reviewing applications for re- zoning, the court has ruled <br />that the city continues to act in a legislative capacity, even though the re- <br />zoning application may only relate to one specific parcel owned by one <br />individual. The existing zoning ordinance is presumed to be constitutional, <br />and an applicant is only entitled to a change if they can demonstrate that the <br />existing zoning is unsupported by any rational basis related to the public <br />health, safety and welfare. <br />2. Making a record of the basis for zoning <br />decisions <br />The 60 -Day Rule requires the city to provide reasons for its denial of a <br />zoning request. These reasons for denial must be stated on the record. In <br />addition, the city must provide the applicant with a written statement of the <br />reasons for denial. The reasons for denial or approval, whether written or <br />stated on the record are considered the city's "findings of fact" on the <br />application if later court review of the city's decision is necessary. <br />32 LEAGUE OF MINNESOTA. CITIES <br />