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Lupe Development Partners v. City of Minneapolis

Citations: 472 N.W.2d 692; 1991 Minn. App. LEXIS 780; 1991 WL 145743Docket: No. C9-90-2668

Court: Court of Appeals of Minnesota; August 6, 1991; Minnesota; State Appellate Court

Narrative Opinion Summary

In this case, Lupe Development Partners sought to convert a fraternity house into a rooming house within an R-5 residential district. The City of Minneapolis opposed this conversion, citing zoning ordinance restrictions. Lupe argued that their intended use was 'substantially similar' to the prior use of the property, which should allow for the conversion under existing zoning provisions. However, both the Minneapolis Board of Adjustment and the City Council unanimously rejected Lupe's proposal, prompting Lupe to file a declaratory judgment action. The trial court granted summary judgment in favor of the City, finding that the proposed use did not meet the 'substantially similar' criteria necessary for approval. The court emphasized that rooming houses are only permissible in R-5 districts if they adhere to specific historical and structural criteria, which the subject property did not satisfy. As a result, the court concluded that no material fact issue existed and upheld the City's decision as a matter of law, affirming the prohibition of the proposed conversion.

Legal Issues Addressed

Permissible Uses in Zoning Districts

Application: The court confirmed that rooming houses are permissible in R-5 zoning districts only if they meet specific criteria, which the proposed conversion did not.

Reasoning: Currently, rooming houses are allowed in R-5 zoning districts, defined specifically as buildings that were single-family or two-family dwellings on July 19, 1963, which have been converted for three or more non-family members, with no meal service provided.

Substantially Similar Use

Application: The court ruled that the proposed use of the property as a rooming house was not substantially similar to its prior use as a fraternity house, thus not permissible under the zoning ordinance.

Reasoning: The court emphasized that the 'substantially similar' provision applies only when the use is not explicitly provided for in the zoning ordinance.

Summary Judgment Standards

Application: The court found no material issue of fact and upheld the summary judgment in favor of the City, indicating that the City was entitled to judgment as a matter of law.

Reasoning: The issue before the court was whether the trial court erred in its ruling, with the conclusion that no material issue of fact existed, and that the City was entitled to judgment as a matter of law.

Zoning Ordinance Interpretation

Application: The trial court interpreted the zoning ordinance to prohibit the conversion of a fraternity house into a rooming house due to a lack of substantial similarity in use.

Reasoning: The trial court granted summary judgment in favor of the City of Minneapolis, determining that Lupe Development Partners' proposal to convert a fraternity house into a rooming house was prohibited by the zoning ordinance.