Duncan v. Village of Middlefield

In Kisil v. Sandusky, supra, this court held in the syllabus:

“The standard for granting a variance which relates solely to area requirements should be a lesser standard than that applied to variances which relate to use. An application for an area variance need not establish unnecessary hardship; it is sufficient that the application show practical difficulties.”

*86In adopting the lesser, practical difficulties standard for area variances, we relied, in part, upon the analysis of the New York Court of Appeals in Matter of Hoffman v. Harris (1966), 17 N.Y. 2d 138, 269 N.Y. Supp. 2d 119, 216 N.E.…