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286 Minn. 552 NORTH WESTERN REPORTER, 2d SERms 1554 (1960), quoted in Connolly v. Pension Benefit Guar. Corp., 475 U.S. 211, 227, 106 S.Ct. 1018, 1027, 89 L.Ed.2d 166 (1986). [3] The parties generally agree that the challenged governmental action passage and enforcement of the ordinance did not consti- tute a per se taking. Arcadia does not claim there has been an actual taking of title or pennanent physical invasion of ' the property; nor does Arcadia claim that it was denied all economically beneficial or productive use of the property. See Yee v~ City of Escondida, 503 U.S. 519, 527-28, 112 S.Ct. 1522, 1528, 118 L.Ed.2d 158 (1992) (stringent mobile home rent control ordinance not physical tak- ing of park owner's property); Lucas v. Sooth Carolina Coastal Cooncil, 505 U.S. 1003, 1015, 112 S.Ct. 2886, 2893, 120 L.Ed.2d 798 (1992). While Arcadia claims the value of the property diminished as a result of the ordinance, that alone is insufficient to demon- strate an actual or per se taking has oc- curred. See Concrete Pipe & Prods. v. Con- struction Laborers Pension Trust, 508 U.S. 602, 645, 113 S.Ct. 2264, 2291, 124 L.Ed.2d 539 (1993) (''mere diminution" in value of property, however serious, is insufficient to demonstrate a taking); 614 Co. v. Minne-. apolis Community Dev. Ag., 547 N.W.2d 400, 406 (Minn.App.1996) (property may be "tak- en" when owner alleges temporary depriva- tion of all economically beneficial or produc- tive use of land). \ [4] The parties disagree on the correct standard to be applied. The City and State, as amicus, characterize the ordinance as a fonn of land-use regulation. See Yee, 503 U.S. at 527-30, 112 S.Ct. at 1528-29 (local legislation regulating the economic relation- ship between mobile home park owners and residents is a fonn of land-use regulation). They insist that the applicable takings stan- dard is whether the ordinance substantially advances a legitimate governmental purpose. See Dolan v. City of Tigard, 512 U.S. 374, -, 114 S.Ct. 2309, 2316, 129 L.Ed.2d 304 (1994) (legislative land-use regulation which neither fits within per se category nor trans- fers property to government "does not effect a taking if it 'substantially advancers] legiti- mate state interests' ") (quoting Agins v. City ofTiburcm, 447 U.S. 255, 260,100 S.Ct. 2138.;' 2141, 65 L.Ed.2d 106 (1980)). . Arcadia insists that a more onerous stan.. . dard applies. That standard, also an-~- nounced in Dolan, places the burden on the! government to make an individualized deter. J mination establishing that compliance With '. governmental conditions bear a "rough pl'\). , portlonality," in both nature and extent, to the impact of those conditions. Dolan,_ U.S. at - - -, 114 S.Ct. at 2319-20. This analysis, however, applies only to adju. dicative detenninations that condition ap- proval of a proposed land use on a property transfer to the government, which, standing alone, would clearly constitute a taking. I d. at -, 114S.Ct. at 2316. Accordingly, cases interpreting Dolan have confined its "rough proportionality" analysis to adjudica. tive land-dedication situations or to classic "subdivision exaction" cases. See, e.g., Cla- jon Prod. Corp. v. Petera, 70 F .3d 1566, 1578-79 & 1579 n. 21 (10th Cir.1995); Kott- schade v. City of Rochester, 5.~7 N.W.2d 301, 307~8. (Minn.App.1995) (Dolan's "rough proportionality" test met in case where the city required a- developer to "dedicate land for street and highway improvements as a condition for subdivision approval"), review denied (Minn. Nov. 15, 1995). Because this case involves a challenge to a citywide, legis- lative land-use regulation, Dolan's ''rough proportionality" test does not apply. [5] The issue thus becomes whether the ordinance substantially advances a legitimate governmental purpose. Governments have broad powers and legitimate interests in reg- ulating housing conditions in general and the landlord-tenant - relationship in particular. Yee, 503 U.S. at 528-29, 112 S.Ct. at 1529. More specifically, Minnesota has long regu- lated the mobile home park industry to pro- tect park residents. See Minn.Stat. ~~ 327.81-.36 (manufactured home building code); 327B.Ol-.12 (manufactured home sales); 327C.Ol-.15 (manufactured home park lot rentals). Thus, the purposes of the ordinance and the 1987 enabling legislation are without question real and legitimate: protecting mobile home park residents from severe or complete losses of substantial in- vestments in their homes when the park '-, ". '. ", . . ~ .~: ~;' ~ ,~ '- , I ~; ;~ Ff~ -~, ff. .~~: ," 'l ~~. "./. ,::, .i ~r .'\t . ~~ ~ .~~