Mennonite Board of Missions v. Adams
United States Supreme Court
462 U.S. 791 (1983)
Mennonite Board of Missions (MBM) (defendant) sold a property to Alfred Jean Moore, who executed a mortgage on the property in favor of MBM to secure a $14,000 debt. The mortgage was recorded in Elkhart County, Indiana (the County). Unbeknownst to MBM, Moore failed to pay property taxes. Eventually, the County commenced proceedings to sell the property for nonpayment of taxes. In accordance with Indiana law, the County provided notice of the tax sale by: (1) publication, (2) posting in the county courthouse, and (3) mail sent directly to Moore. Moore did not inform MBM of the tax sale. The property was sold to Richard Adams (plaintiff) for $1,167.75. Because Moore continued to make mortgage payments to MBM, it had no knowledge of the property’s sale. MBM learned of the sale two years later, at which point the redemption period had expired and Moore still owed $8,237.19 to MBM. Adams filed a suit in an Indiana state court to quiet title to the property. MBM opposed Adams’ action on the basis that it had not received constitutionally adequate notice of the sale or the opportunity to redeem. The trial court concluded that the notice provided was constitutional; the Indiana Court of Appeals affirmed. MBM petitioned the United States Supreme Court for certiorari.
Rule of Law
Holding and Reasoning (Marshall, J.)
Dissent (O’Connor, J.)
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