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Looking at the 3-D model of cyclopropane, there is no conformation that could result in the 3 carbon molecules to not be in the same plane. For cyclobutane, two of the carbons can go up or down together, creating a non planar formation (butterfly) which is more stable because there is less torsional strain.
The Carbon atoms in cyclobutane, unlike cyclopropane, can rotate to stagger the hydrogen atoms and relieve torsional strain. Cyclopropane must be planar, and cyclobutane takes a butterfly confirmation because it is more stable this way than as planar.
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