In 2021, a Pennsylvania property was sold at a tax sale; one owner's notice challenge changed the case; what exactly happened?

A Pennsylvania property was sold at a judicial tax sale. However, an appeals court then ordered the sale set aside after the county failed to notify the current owners when the sale was rescheduled.

The case in focus is Satoria Johnson v. Tax Claim Bureau of Delaware County and Stephen Davis.

What was the case all about?

It was located at 4168 Oliver Lane in Upper Chichester, Delaware County, Pennsylvania. Satoria Johnson and her brother acquired ownership of the property.


James and Lois Jacono were the previous owners of the property.

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It faced a tax-sale process only because the county's Tax Claim Bureau was seeking to recover unpaid property taxes.

In order to sell the property, the Tax Claim Bureau petitioned the Delaware County Court of Common Pleas on January 20, 2021. The hearing then took place on April 5 and the court scheduled the judicial sale for May 13, 2021.

The sale faced an interruption on May 10, as Johnson's brother asked the US bankruptcy court to stop the proceedings.

But, the property was sold on September 16, 2021 at a judicial tax sale. The bidder was Stephen Davis.

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Why was the sale challenged?

Johnson filed a petition and asked the court to set aside the sale. Her argument was the owner, but was not even informed that the judicial sale would take place in September.

Johnson's petition was rejected by the lower court. The September sale was treated as a continuation of the original proceedings and reasoned that Johnson had implied knowledge of sale through the related bankruptcy case. But, Johnson appealed the decision.

What was the court's ruling?

The reasoning of the lower court was disagreed by the Pennsylvania Commonwealth Court.

The court found no evidence that Johnson was notified about the judicial sale that happened in September. The lower court's order was reversed. It was then sent back with instructions to set aside the September 2021 judicial sale.