AES Drilling Fluids, LLC v. Clearfield County TCB

CourtCommonwealth Court of Pennsylvania
DecidedJune 9, 2025
Docket583 C.D. 2023
StatusUnpublished

This text of AES Drilling Fluids, LLC v. Clearfield County TCB (AES Drilling Fluids, LLC v. Clearfield County TCB) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AES Drilling Fluids, LLC v. Clearfield County TCB, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

AES Drilling Fluids, LLC, : Appellant : : v. : : No. 583 C.D. 2023 Clearfield County Tax Claim Bureau : Argued: April 8, 2025

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE FIZZANO CANNON FILED: June 9, 2025

AES Drilling Fluids, LLC (AES) appeals from the May 4, 2023, order of the Court of Common Pleas of Clearfield County (trial court). The trial court’s order denied AES’s objections to the tax sale of property previously owned by AES in Clearfield County (County). Upon review, we reverse.

I. Factual & Procedural Background On October 13, 2022, the Clearfield County Tax Claim Bureau (Bureau) filed a consolidated return of sale of properties for unpaid tax claims with the trial court. Reproduced Record (R.R.) at 1a-4a. The filing stated that various properties in the County had unpaid liens and claims for the 2020 tax year and that a tax sale for those properties had been scheduled for September 16, 2022. Id. at 2a. The Bureau averred that it had advertised the sale in three local newspapers in August 2022 and attached proof of those publications. Id. The Bureau stated that it had informed property owners of the impending sale by sending them notices via “certified mail, restricted delivery, return receipt requested” and posting notices of the sale on the properties. Id. at 2a-3a. The sale had taken place as advertised. Id. at 3a. The filing stated that on October 3, 2022, post-sale notice was provided to the owners that the properties were sold and advising the owners of their right to object to the sale within 30 days after the trial court’s conditional confirmation nisi of the consolidated return. Id. A parcel owned by AES was listed at a delinquency price of $1,011.10 and sold for $3,000.00 to Property Development, LLC, which intervened in this matter and joins the Bureau’s brief to this Court. R.R. at 14a. The October 3, 2022, notice to AES regarding that property was sent to AES at P.O. Box 3075, McKinney, TX 75070 (the McKinney address). Id. at 36a. On October 20, 2022, the trial court issued an order confirming nisi the sales. R.R. at 35a. On November 16, 2022, AES filed a timely objection and petition to set aside the sale on the basis that the Bureau failed to comply with the notice and service provisions of the Real Estate Tax Sale Law (RETSL),1 which establishes the procedures for collection of taxes through upset sales and judicial sales and for objecting to such sales. R.R. at 37a. Specifically, AES averred that the Bureau failed to properly notify AES of the underlying claim for tax delinquency via “notice of return and claim” because the notices were sent to the McKinney address, which is no longer correct. Id. at 39a-47a & 57a. AES also alleged that the Bureau failed to properly notify it by mail of the sale and did not comply with the RETSL’s requirements for public posting of the notice of sale at the property. Id. AES attached to its objection copies of documents it stated it received after requesting the Bureau’s file on this matter. These included a green certified

1 Act of July 7, 1947, P.L. 1368, as amended, 72 P.S. §§ 5860.101-.803.

2 mail card from the McKinney address that appears to have been signed as received on April 16, 2021; a May 2022 notice of the September 2022 sale sent by the Bureau to the McKinney address; the notarized affidavit of Holly McGovern (McGovern), who posts the County’s property notices, attesting that she personally served and posted the notice on July 13, 2022;2 a piece of returned first class mail sent by the Bureau to the McKinney address in August 2022 before the sale; a green certified mail receipt and green card indicating receipt of an item mailed from Clearfield to the McKinney address on September 30, 2022, about two weeks after the sale; and a piece of returned first class mail sent by the Bureau to the McKinney address on September 30, 2022. Id. at 57a-62a. The trial court held a hearing on January 12, 2023. Heather Clark (Clark), an administrative tax assistant with the Bureau, testified that on May 6, 2022, the Bureau issued a notice of tax sale for the relevant parcel. R.R. at 127a. She confirmed that such notices were to be sent by certified mail with restricted delivery and a signature upon receipt. Id. She acknowledged that in preparation for the hearing, she did not find a signed green certified mail return card for the May 2022 notice of sale in the file of this matter. Id. at 128a. She stated, however, that the mailing was not returned and that tracking information showed that it was delivered to the McKinney address. Id. The record includes the May 2022 notice, which was addressed and sent to AES via restricted delivery at the McKinney address, and the corresponding postal service tracking printout reflecting delivery and pick up at the McKinney post office on May 16, 2022. Id. at 79a-81a. Clark noted that the file did include a signed and returned green card for the post-sale notice also sent to the McKinney address. Id. at 129a.

2 In McGovern’s subsequent hearing testimony summarized below, she acknowledged that she did not actually physically post the notice on the property on that date.

3 Clark testified that the Bureau gets the names and addresses of taxpayers from the county assessor’s office. R.R. at 132a. Her office relied on that information and she did not personally cross-reference the addresses. She confirmed printouts from the assessor’s office for two AES-owned properties in the County that had different addresses: the subject parcel showed the McKinney address for AES while the other parcel showed AES’s mailing address to be P.O. Box 460389, Houston, TX 77056 (Houston address). Id. at 133a; see also id. at 91a-92a. Another printout showed that local property taxes on the subject parcel were billed by the County tax collector to the incorrect McKinney address but local school taxes on the subject parcel were billed to the correct Houston address. Id. at 136a; see also id. at 100a-101a. The record also includes a copy of an April 1, 2021, school tax bill for 2020 for the parcel with the office building on it; the bill is addressed to the correct address in Houston and was paid with an AES check dated April 30, 2021. Id. at 104a-05a. Clark acknowledged that the Bureau’s notices regarding the September 2022 sale were not sent to the Houston address. Id. She confirmed that in August 2022, a 10-day notice of the sale had been sent by first class mail to the McKinney address but was returned undelivered. Id. at 164a & 166a. She was unaware if any additional efforts were made by the Bureau in August to notify AES of the upcoming sale and no documentation of such efforts was in the file for this matter. Id. at 164a- 65a. However, she stated that if the initial notice of sale sent in May 2022 had been returned undelivered, the Bureau would routinely have followed up with additional notice efforts. Id. at 166a. During the hearing, the Bureau’s counsel acknowledged that with regard to the initial notice and return of the underlying claim, the Bureau “does not

4 have a copy of the actual mailing. Only a green card returned, but I will state we do not have a copy of the actual return itself to indicate what it stated on it as far as the tax claim statute would require.” R.R. at 152a-53a. Lisa Conrad (Conrad), the County’s assessor, testified that if the tax collector determines that a property’s owner is at a different address from the assessor’s office records, the collector should notify the assessor’s office of the change, but this is not always the case. R.R. at 139a-40a & 142a-43a. She stated that if a piece of mail is signed for as delivered to the recipient, the Bureau will not have a reason to think there might be another address.

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836 A.2d 1037 (Commonwealth Court of Pennsylvania, 2003)
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AES Drilling Fluids, LLC v. Clearfield County TCB, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aes-drilling-fluids-llc-v-clearfield-county-tcb-pacommwct-2025.