Patricia A. Langon v. Kevin M. Reilly

Summary

The District of Columbia Court of Appeals affirmed the trial court's ruling that Patricia Langon's tax deed was insufficient to quiet title. The court held that the District failed to provide required notice of the tax sale to the property owner's conservator, invalidating the tax sale, and further held that the 90-day conclusive-presumption provision in D.C. Code § 47-1303.04(f)(4) did not apply to a deed issued by the Mayor under § 47-1304.

Holdings

1. The evidence was sufficient to support the trial court's finding that the District failed to notify the taxpayer's conservator of the impending tax sale.
2. D.C. Code § 47-1303.04(f)(4)'s ninety-day conclusive-presumption and jurisdictional restriction applies only to deeds issued pursuant to § 47-1303.04, not to the deed issued to Langon by the Mayor under § 47-1304.
3. A valid conveyance of property for nonpayment of real estate taxes requires strict compliance with the applicable tax-sale statutes and regulations; failure to comply renders the sale invalid and subject to being set aside.

Questions Presented

1. Whether the evidence was sufficient to support the trial court's finding that the District of Columbia failed to provide proper notice of the tax sale.
2. Whether D.C. Code § 47-1303.04(f)(4) deprived the Superior Court of authority to consider the validity of Langon's tax deed because the action was filed more than ninety days after the deed was recorded.

Disposition

affirmed