257-261 20th Avenue Realty, LLC v. Alessandro Roberto

CourtSupreme Court of New Jersey
DecidedJanuary 9, 2025
DocketA-29-23
StatusPublished

This text of 257-261 20th Avenue Realty, LLC v. Alessandro Roberto (257-261 20th Avenue Realty, LLC v. Alessandro Roberto) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
257-261 20th Avenue Realty, LLC v. Alessandro Roberto, (N.J. 2025).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

257-261 20th Avenue Realty, LLC v. Alessandro Roberto (A-29-23) (088959)

Argued September 23, 2024 -- Decided January 9, 2025

RABNER, C.J., writing for a unanimous Court.

In this appeal, the Court considers whether the version of the Tax Sale Law (TSL) in effect prior to the law’s amendment in 2024 violates the Takings Clause of the Fifth Amendment to the United States Constitution.

Defendant Alessandro Roberto bought a property in Paterson in 1997; in 2022, a realtor estimated the property could be listed for up to $535,000. Roberto failed to pay three sewer tax bills on the property totaling $606. The City of Paterson placed tax liens on the property for that amount, and plaintiff 257-261 20th Avenue Realty, LLC, bought the corresponding tax sale certificates at public auction. Years later, plaintiff filed a tax foreclosure complaint. The trial court set the amount of redemption at $32,973.15. Roberto did not answer the complaint or pay the redemption amount, and the court entered a judgment in plaintiff’s favor.

Within two months of the final judgment, Roberto moved to permit redemption under Rule 4:50-1, arguing that he had posted $50,000 in escrow to redeem the property; that he had invested about $200,000 in improvements to the property since its purchase; and that, at age seventy-five, the “[p]roperty was crucial to [his] retirement because it ha[d] over several hundred thousand dollars in equity” beyond the amount of past taxes owed. The trial court ultimately vacated the judgment under Rule 4:50-1(f), which allows for judgments to be set aside in exceptional circumstances. Plaintiff appealed.

While the appeal was pending, the Supreme Court decided Tyler v. Hennepin County, 598 U.S. 631 (2023), holding that a homeowner -- faced with forfeiture of the surplus equity in her home under Minnesota’s tax foreclosure law -- had plausibly alleged a taking in violation of the Fifth Amendment. The Appellate Division concluded that Tyler provided cause to vacate judgment and affirmed. 477 N.J. Super. 339, 350, 362 (App. Div. 2023). It also held that, under New Jersey precedent, Tyler should be given pipeline -- not full -- retroactivity, and it separately found that the trial court did not abuse its discretion in granting relief under Rule 4:50-1(f). Id. at 363, 368. The Court granted certification. 256 N.J. 535 (2024). 1 HELD: The applicable version of the TSL in this case is unconstitutional to the extent it allows for the forfeiture of surplus equity without just compensation. New Jersey recognizes a property right to surplus equity in real property, and because private lienholders act jointly with local government under the TSL to perform a traditional public function -- the collection of taxes -- they may be considered state actors. The Court rejects the argument that the surplus equity initially foreclosed in this case was not taken for a public use. The Court affirms as modified the judgment of the Appellate Division based on the reasoning in Tyler; it does not rely on Rule 4:50-1(f).

1. The Court reviews New Jersey’s tax foreclosure law before its amendment in 2024. The statutory amendments have no effect on this appeal. Tyler, however, materially affects the legal issues presented, so the Court does not resolve whether exceptional circumstances within the meaning of Rule 4:50-1(f) were present in this case. It instead notes that Roberto’s motion was timely and that it does not adopt the Appellate Division’s analysis under the Rule. (pp. 10-18)

2. The Takings Clause of the Fifth Amendment provides that “private property” shall not “be taken for public use, without just compensation.” U.S. Const. amend. V. In Tyler, the Supreme Court evaluated the Takings Clause in the context of the foreclosure of a private home under Minnesota’s tax foreclosure scheme. 598 U.S. at 634-35. In doing so, the Supreme Court looked to state law, traditional property law principles, historical practice, and precedent. Id. at 638. The Tyler Court noted that Minnesota recognized a homeowner’s right to equity in real property. Ibid. As a result, although “[t]he County had the power to sell Tyler’s home to recover the unpaid property taxes[,] . . . it could not . . . confiscate more property than was due” -- a principle traced back to the Magna Carta. Id. at 639. The Tyler Court also considered other contexts in which Minnesota law recognized that “a property owner is entitled to the surplus in excess of her debt.” Id. at 645. The Court explained that “[t]he Takings Clause ‘was designed to bar Government from forcing some people alone to bear public burdens.’” Id. at 647. Under the facts of Tyler’s case, “[a] taxpayer who loses her $40,000 house to the State to fulfill a $15,000 tax debt has made a far greater contribution to the public fisc than she owed.” Ibid. (pp. 18-21)

3. As binding precedent of the United States Supreme Court, Tyler applies to pending federal cases on direct review, Harper v. Va. Dep’t of Tax’n, 509 U.S. 86, 97 (1993), and to cases on direct review in state court, Reynoldsville Casket Co. v. Hyde, 514 U.S. 749 (1995). This case is not final; it is still pending. The Court therefore agrees with the Appellate Division that Tyler applies here, but it reaches that conclusion because Harper and Reynoldsville so require, not based on a retroactivity analysis under New Jersey precedent. And because Roberto’s claim is on direct review, the Court does not address the Appellate Division’s determination that Tyler should not receive full retroactivity in other cases. Nor does the Court 2 decide whether a party may file a claim for just compensation alone when a foreclosure has been finalized and a taking of equity has already occurred, but the taking is within the relevant statute of limitations. (pp. 21-25)

4. Plaintiff contends Tyler should not apply to New Jersey’s tax foreclosure scheme. First, plaintiff argues that New Jersey did not recognize a protected property right to surplus equity when the equity in Roberto’s property was taken. The Court reviews the historical and traditional legal principles relating to surplus equity, as the Supreme Court did in Tyler, and concludes that property owners in New Jersey do have a recognized property right to surplus equity. Plaintiff next argues that private lienholders are not state actors, so their conduct is not subject to the Takings Clause. But the collection of tax revenue is a quintessential, traditional public function. Real estate taxes are the primary source of revenue for local governments. Lienholders on their own cannot facilitate the collection of delinquent property taxes or create an alternate stream of revenue for the town under the TSL; nor can they transfer title through a tax foreclosure. Local government and private lienholders act jointly in that regard. And their interdependent actions flow from the statutory scheme the State created -- the TSL. Private lienholders who execute tax foreclosures may thus be considered state actors. Finally, plaintiff argues that any equity foreclosed in this case was not taken for a public use and would therefore not run afoul of the Fifth Amendment. The argument is self-defeating because even if a lienholder took surplus equity in property for a private use, they could not keep it.

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257-261 20th Avenue Realty, LLC v. Alessandro Roberto, Counsel Stack Legal Research, https://law.counselstack.com/opinion/257-261-20th-avenue-realty-llc-v-alessandro-roberto-nj-2025.