Laserfiche WebLink
1~-~3-1W~ O~:SWMM PRUM DURN LNW PIR~, LIO qWFDDqJ K.~ <br /> <br />510 N.W.2d 264, R.A. Putnam & Associates, Inc. v. City of Mendota Heights, Dakota County, <br />(Mm. App. 1994.) <br /> <br />Page 4 <br /> <br /> 9. While the City's Comprehensive Plan was <br />changed in 1985 to designate this property to I-IR- <br />PUD, a number of substantial changes have taken <br />place in the southeast area of the City since that time <br />which may render such designation inappropriate. <br /> <br />*267 The council adopted the resolution at its next <br />scheduled meeting, oa May 5, 1992. <br /> <br /> Putnam and Rotflund then brought an action to <br />compel the city to rezone the property, issue a <br />conditional use permit, and approve the sketch plan. <br />The district court limited its review to the record that <br />was before the city council at the time of the <br />council's decision. (PNI) In June 1993, the court <br />concluded that the city's action was arbitrary and <br />without factual basis and ordered the city to rezone <br />the property HR-PUD, grant a conditional use <br />pcrrnit, and approve the sketch plan. <br /> <br />ISSUES <br /> <br /> 1. Did the district court err by concluding that the <br />city failed to properly record the basis for its zoning <br />decision? <br /> <br /> 2. Did the district court err by ordering the city to <br />rezone the property, grant a conditional use permit, <br />and approve the sketch plan? <br /> <br />ANALYSIS <br /> <br /> [1] This court independently examines a city's <br />denial of a rezoning request. St. Cmix Dev., Inc. v. <br />City of Apple Valley, 446 N.W.2d 392, 397 <br />(Minn. App. 1989), Vet. for rev. denied (Minn. D~. <br />I, 1989). We do not accord any special deference to <br />the district court's review of the city's action. Id. <br /> <br /> [2][3] 1. Rottlund and Putnam contend that the <br />city's failure to make contemporaneous findings <br />created a presumption that the city's actions were <br />arbitrary. If a city council fails to record the basis <br />for a zoning determination at the time it acts, the <br />zoning action is presumed to be arbitrary. Zylka v. <br />City of Crystal, 283 Minn. 192, 198, 167 N.W.2d <br />45, 50 (1969). In this case, the planning commission <br />prepared a written recommendation, the council <br />videotaped its hearings, and the city took minutes of <br />the planning cor~miasion and city council hearings <br />and transcribed the council meetings at which reasons <br />for the denial were discussed. This was enough to <br />preclude a presumption of arbitrariness. See. <br />Swanson v. City of Bloomington, 421 N.W,2d 307, <br /> <br />312 (Minn. 1988). <br /> <br /> [4][5] Even if this record had not been created, the <br />resolution adopted at the May 5 council meeting was <br />an adequate contemporaneous record. Thc <br />require~me~_t that contemporaneous findings be <br />recorded prevents a city from offering "after-the-fact <br />justifications * * * unrelated to the actual reasons for <br />the initial decision." Uniprop Manufactured Hous. v. <br />City of Lakeville, 474 N.W. 2d 375, 379 <br />(Minn.App. 1991), bet. for rev. den~ed (Minn. Oct. <br />11, 1991). This rationale is not served by denying a <br />city a reasonable amount of time to prepare a record <br />or formalize its findings. We conclude that as long <br />as the necessary record is prepared within a <br />reasonable time of a zoning decision, a municipality <br />should not be presumed to have acted in an arbitrary <br />manner. See BBY Investors v. City of Maplewood, <br />467 N.W.2d 631, 635 (Minn. App. 1991) (findings <br />made contemporaneously where council in process of <br />drafting and adopting them 26 days after hearing and <br />vote), pet. for rev. denied (Minn. May 23, 1991). <br /> <br /> [6][7] Whether the record has been prepared in a <br />reasonably timely fashion is a question that must be <br />considered in light of the facts surrounding the <br />zoning decision, such as the complexity of the issues <br />involved in reaching that decision. Here, the city <br />was presented with a relatively complex rezoning <br />requ,est and extensive documentation. The council <br />adopted findings two weeks after the hearing, at its <br />next scheduled meeting. Under these facts, we hold <br />that the city's formal findings were prepared and <br />adopted within a reasonable time. <br /> <br /> [8][9] 2. We must still determine whether the city's <br />findings and decision were arbitrary. A zoning <br />decision should not be disturbed if a city gives legally <br />sufficient reasons, and the reasons are grounded in <br />fact. NBZ Enters., Inc. v. City of Shakopee, 489 <br />N.W.2d 531, 537 (Minn. App. 1992), pet. for_rev. <br />de,ed (Minn. Sept. 30, 1992). In other *268. <br />words, a court should not interfere with a municipal <br />zoning decision that has a "rational basis" or is <br />"reasonably debatable." Swanson, 421 N.W.2d at <br />314; Honn v. City of Coon Rapids, 313 N.W.2d <br />409, 417 (1981). <br /> <br /> [10] The city council offered several ]egally <br />sufficient reasons in support of its denial of the <br />zoning request. For example, the council was <br />concerned that Rottlund's project was not <br />appropriately sealed in light of the surrounding land <br />use. This reason finds factual support in the recent <br /> <br />Copyright (c) West Group 1998 No c]a~m to origir~l U.S. Govt. works <br /> <br /> <br />