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Mr. Ornstein Page 7 argument might home park also fail unless the existing use as a manufactured is unreasonable. It appears that this factor would depend upon uses are available what is reasonable another situation. the circumstances. It would depend upon what for the property in question. Furthermore, in one situation may not be reasonable in If, on the.other hand, a court should find that the statute serves an enterprise function, or a combination arbitration - enterprise function as in the Pratt case, a park owner would have to show that the property has suffered a substantial and measurable diminution in market value because of the statute. However, often a regulation will vastly decrease the worth of a piece of property by prohibiting even the most valuable use of it. Courts consistently have said that this does not necessarily give rise to a compensable taking. E.g., Euclid v. Ambler Realty, 272 U.S. 365, 47 S. Ct. 114 (1926) (75% diminution in value found not to constitute a taking); Hadacheck v. Sebastian, 239 U.S. 394, 36 S. Ct. 133 (1915) (diminution in value from $800,000 to $60,000 upheld).4 Mere diminution in value, by itself, cannot establish a taking. Andrus v. Allard, 444.U.S. 51, 100 S. Ct. 318 (1979); Penn Central, 98 S. Ct. at 2663. The other factors in the analysis play a role as well. In Connolly, the regulation at issue completely deprived a participating employer of "whatever amount of money it is obligated to pay to fulfill its statutory liability." 475 U.S. at 225. The court noted, however, that the assessment was made because of the relationship between the employer and the pension plan in which it had voluntarily participated. The court gave significance to the fact that the act had numerous provisions which moderated and mitigated the economic impact upon the individual property owner. Id. Also, giving yet another indication that such analysis depends upon the circumstances of a given case, the court noted that there was no showing that "the / The Minnesota courts repeatedly have upheld land -use regulations claimed to be unconstitutional takings where the property value has declined substantially as a result of the regulations. McShane, 292 N.W.2d 257, citing State. by Powderly v. Erickson, 285 N.W.2d 85 (Minn. 1979); Holoway v. City of Pioestone, 269 N.W.2d 28 (Minn. 1978); Beck v. City of St. Paul, 304 Minn. 438, 231 N.W.2d 919 (1975); Connor v. Township of Chanhassen, 249 Minn. 205, 81 N.W.2d 789 (1957); Alexander Co. v. City of Owatonna, 222 Minn. 312, 24 N.W.2d 244 (1946).