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• 4. The need for a county road which served local traffic (even though the subdivision was not allowed direct access to the road) might have a sufficient relationship to the local traffic, of which the subdivision was a part, to support the dedication requirement.ea 5. The recent United States Supreme Court decision of Dolan v. City of Tigard55 requires that the government prove the validity of its exaction requirements. The government must prove a "rough proportionality", that the "required dedication is related both in nature and extent to the impact of the proposed development." This appears to be the same as the "reasonable relationship" test used by the Minnesota Supreme Court. 6. Further, the Do/an case requires an individualized determination that there is a rough proportionality in each case. This raises serious doubt about whether cities may use a standard park dedication fee. ~/l~. JUDICIAL REVIEW. A. The Record for Court Review. • 1. If the city has made findings contemporaneously with its action and there is an accurate verbatim transcript of the proceedings, the record of the proceedings before the city council is likely to be clear and complete. In that case, the judge should review the city record without the need for additional evidence at trial.ss 2. The parties may submit additional evidence to the judge, but only if it relates to issues considered by the council and only if there were good reasons why it was not presented to the council.57 3. Cities should at least tape record their meetings and provide adequate opportunity for the interested parties to speak and comment on the evidence presented. By doing so, the parties will be able to avoid the costs of a trial. The case can be decided on a motion for summary judgment, based on the record. B. Standard of Review. The standard for reviewing all land use decisions is whether the council's action was reasonable, based on rational reasons.58 • 9