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,RIES , . 255, 260, 100 S.Ct. 21~ '" i (1980)). -.. : at a more onerous stan- -f- at standard aI :, , so an- .laCes the burden on th ' . an individualize e d deter. ~ that compliance With IOns bear a ''rough Pro.. 1 nature and extent, to conditions. Dola~_ 114 S.Ct. at 2319-20 :!I', applies only to adju~ )DS that condition ap.. land use on a property nme~t, which, standing :onstitute a taking. fa. at 2316. Accordingly, Jlan have confined its r' analysis to adjudica- ;ituations or to classic cases. See, e.g., Cia- ~etera, 70 F.3d 1566 (lOth Cir.1995); Kott~ ester, 5.17 N.W.2d 301 ~5) (Dolan'8 ''rough !let in case where the 'per to "dedicate land :y improvements as a on approval"), review ,1995). Because this ~e to a citywide, legis- jon, Dolan'8 ''rough es not apply. becomes whether the advances a legitimate Governments have mate interests in reg- ns in general and the rlShip in particular. J, 112 S.Ct. at 1529. esota has long regn- >ark industry to pro- ,See Minn.Stat. tured home building nanufactured home nanufactured home the purposes of the enabling legislation eal and legitimate: park residents from !S of substantial in- .es when the park ~@.-.' -. i;.i ;.~ '?J;, I .~ ~~.j' .f ~~~~, ,~ :;~:, ~~~ ~. :;t. .~~ ~: .~. :~" "(-..1'. ~. ~f .~ '~f /' f ',. '.~ Minn. 287 ARCADIA DEVELOP. v. CITY OF BLOOMINGTON Clteas552 N.W.2d 281 (M1nn.App. 1996) decides to close their park by selling 112 S.Ct. at 1526 ("Mobile homes are largely ,.n:-nd or changing its use. See Adamson immobile as ~ practic~ matter, be~w:e the the, 11. City of Malil1u, 854 F.Supp. at 1488- cost of movmg one 18 often a s~gnificant OJ& 1493 (both rent control and closure re- fraction of the value of the mobile home ~etions that protect investments made by itself."). By requiring a park owner to pay bile home park tenants in their homes mitigation fees or relocation costs to dis- 1110 legitimate governmental purposes); placed residents when that owner decides to ~~ 11. Clarke, 121 Wash.2d 586, 854 close its park or change its use, the ordi- p~~ 1,14 (1993) (aiding mobile home owners nance has a direct. nexus or conne~on to the .th relocation expenses caused by park clos- interest of lessemng the econonuc devasta- :g is legitimate public purpose), cert. denied, tion imposed on displaced residents. 610 U.S. 1176, 114 S.Ct. 1216, 127 L.Ed.2d Arcadia asserts that an unconstitutional 663 (1994). taking has occurred because the ordinance [6] Once legitimate governmental inter- unf~ly "singl~s out" or. places the burden of ests are identified, courts simply require a solvmg the CIty'S housmg problems on the exus between the local legislation and the shoulders of a few property owners. Arca- ~gitimate governmental purposes to be dia, h~wever, chose to sell and change the achieved by that le~lation. See Nollan 11. use of Its property and m.ay be called upon to California Coastal Comm'n, 483 U.S. 825, bear the costs of remedymg problems caused 834-37, 107 S.Ct. 3141, 3147-49, 97 L.Ed.2d by its decision. Moreover, Arcadia was not 677 (1987); Adamson, 854 F.Supp. at 1501- precluded from passing on anticipated costs 02. Legitimate governmental interests are of compliance with the relocation ordinance substantially served by legislation seeking to to their tenants in the fonn of rent increases. redistribute benefits and burdens of econom- Finally, as the district court recognized, Ar- . ic life or otherwise to restore an equitable cadia secured some financial benefit following bai..nce to an economic relationship, particu- enactment of the ordinance in the fonn of larly at the end of that relationship. See e.g., lower property taxes and property tax re- Concrete Pipe, 508 U.S. at 640-47, 113 S.Ct. funds. at 2289-92 (corporations withdrawing from multi-employer pension plans required to pay withdrawal liabilities to plan in order to pro- tect remaining plan participants); United States v. Nmheastern Pharmaceutical & Chern. Co., 810 F.2d 726, 734 (8th Cir.1986) (past and present owners of contaminated property required to bear cost of cleaning up contamination under "Superfund" statute), cert. denied 484 U.S. 848, 108 S.Ct. 146, 98 L.Ed.2d 102 (1987); Carpenters Di8t. Coun- cil v. Dillard Dep't Stores, lnc., 778 F.Supp. 318, 325 (E.D.La.1991) (corporations closing plants without notice required to pay wages to workers after date of shutdown). In this case, the immobile nature of mobile homes subjects tenants to extreme financial loss upon park closure; at the same time, this immobility makes the rental of pads profitable for the park owner. See Adam- sO'l'l, 854 F.Supp. at 1488 (park owners in "superior bargaining position" to that of ten- ants even if no shortage of mobile home spaces exists); see also Yee, 503 U.S. at 523, 2. Takings Analysis Under the Minne- sota Constitution [7] The' Takings Clause of the Minnesota Constitution states: "Private property shall not be taken, destroyed or damaged for pub- lic use without just compensation therefor, first paid or secured." Minn. Const. art. I, ~ 13. Minnesota courts generally apply the federal takings standards and examine whether a land-use regulation "deprives the property of all reasonable use." TlwmpsO'n v. City of Red Wing, 455 N.W.2d 512, 516 (Minn.App.1990), review denied (Minn. June 26, 1990); see also Parranto Bros. v. City of New Brightoo, 425 N.W.2d 585, 590 (Minn. App.1988), review denied (Minn. July 28, 1988). When land-use regulations are de- signed to benefit a specific "governmental enterprise," a compensable taking occurs if the property "has suffered a substantial and measurable decline in market value as a re- sult of the regulations." McShane 11. City of Faribaul~ 292 N.W.2d 253, 2~9 (Minn.