  Computing a minimum-area planar straight-line drawing of a graph is known to
be NP-hard for planar graphs, even when restricted to outerplanar graphs.
However, the complexity question is open for trees. Only a few hardness results
are known for straight-line drawings of trees under various restrictions such
as edge length or slope constraints. On the other hand, there exist
polynomial-time algorithms for computing minimum-width (resp., minimum-height)
upward drawings of trees, where the height (resp., width) is unbounded.
  In this paper we take a major step in understanding the complexity of the
area minimization problem for strictly-upward drawings of trees, which is one
of the most common styles for drawing rooted trees. We prove that given a
rooted tree $T$ and a $W\times H$ grid, it is NP-hard to decide whether $T$
admits a strictly-upward (unordered) drawing in the given grid.
