Ex parte J.C. King III PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CIVIL APPEALS

CourtSupreme Court of Alabama
DecidedMay 19, 2023
Docket2022-0653
StatusPublished

This text of Ex parte J.C. King III PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CIVIL APPEALS (Ex parte J.C. King III PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CIVIL APPEALS) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte J.C. King III PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CIVIL APPEALS, (Ala. 2023).

Opinion

Rel: May 19, 2023

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2022-2023

_________________________

SC-2022-0653 _________________________

Ex parte J.C. King III

PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CIVIL APPEALS

(In re: Anderson Realty Group, LLC

v.

J.C. King III)

(Jefferson Circuit Court: CV-20-903660; Court of Civil Appeals: 2201014) SC-2022-0653

STEWART, Justice.

This case concerns the redemption of residential real property sold

at a tax sale, and, in particular, it concerns the definition of the term

"preservation improvements" as used in the applicable redemption

statute, § 40-10-122, Ala. Code 1975. The property at issue ("the

property") had served as a rental home located in a residential

neighborhood. The property owner, J.C. King III, stopped paying

property taxes in 2015 after a fire extensively damaged the property and

rendered it uninhabitable. The State of Alabama purchased the property

at a 2016 tax sale, and in 2019 the property was ultimately sold in its

uninhabitable state to Anderson Realty Group, LLC ("ARG").

ARG spent $88,812 to extensively renovate and restore the property

to a habitable condition,1 and in 2020 it filed a complaint in the Jefferson

Circuit Court seeking to quiet title to the property. King filed a

counterclaim to redeem the property and disputed whether the extensive

renovations to the property could be considered "preservation

improvements" due to be included in the redemption amount pursuant to

1ARG installed new framing, roofing, wiring, plumbing, air conditioning, windows, doors, siding, and gutters.

2 SC-2022-0653

§ 40-10-122(c). The trial court agreed with King, holding that

"preservation improvements" included only those amounts expended by

ARG to keep the property from further deterioration, 2 the value of which

it concluded was $10,000, and it entered a judgment setting the

redemption amount accordingly. ARG appealed, and the Court of Civil

Appeals reversed that judgment, holding that the trial court had erred in

limiting the "preservation improvements" to the cost of repairs

undertaken to keep the property in the same condition it was in at the

time of the tax sale. Anderson Realty Grp., LLC v. King, [Ms. 2201014,

June 10, 2022] __ So. 3d __, __ (Ala. Civ. App. 2022). We granted King's

petition for the writ of certiorari to consider, as a matter of first

impression, the meaning of the phrase "preservation improvements" as

defined in § 40-10-122(d).

Standard of Review

" 'On certiorari review, this Court accords no presumption of

correctness to the legal conclusions of the intermediate appellate court.

2There was testimony that ARG did $10,000 to $12,000 worth of work that could be characterized as merely maintaining the property, i.e., general clean-up work, securing tarps over the roof, landscaping, and lawn maintenance. 3 SC-2022-0653

Therefore, we must apply de novo the standard or review that was

applicable in the Court of Civil Appeals.' " Ex parte Patel, 988 So. 2d 957,

959 (Ala. 2007) (quoting Ex parte Toyota Motor Corp., 684 So. 2d 132,

135 (Ala. 1996)). Here, the question whether the trial court properly

interpreted the phrase "preservation improvements" is a question of law

subject to de novo review. See McKinney v. Nationwide Mut. Ins. Co.,

33 So. 3d 1203, 1206 (Ala. 2009) (noting that a trial court's interpretation

of a statute is a question of law reviewed de novo).

Analysis

When property is sold at a tax sale to a party other than the state,

a process for the redemption of that property is provided by § 40-10-122.

Generally, to redeem property under that section, the party seeking

redemption must pay an amount of money equal to the amount for which

the property was sold (including any funds paid in excess of the

minimum-bid amount), plus any subsequent taxes paid by the purchaser

at the tax sale, with interest -- currently, payable at the rate of 8% per

annum from the date of the sale -- as well as other costs and fees. § 40-

10-122(a). Moreover, the requirements for statutory redemption of

property sold at a tax sale had generally remained the same since the

4 SC-2022-0653

earliest enactment of the statute, regardless of the character or location

of the property at issue. See, e.g., § 608, Ala. Code 1886; § 3111, Ala.

Code 1923; and Title 51, § 305, Ala. Code 1940.

In 2002, however, the legislature passed Act No. 2002-426, Ala.

Acts 2002 ("the 2002 amendment"), which amended § 40-10-122 to

require that additional amounts be paid to redeem property sold at a tax

sale under two distinct circumstances. First, if the property in question

is located within an "urban renewal or urban redevelopment project area

designated pursuant to Chapters 2 or 3 of Title 24 [of the Alabama

Code]," the redemptioner must pay the cost of certain insurance

premiums associated with the property paid by the purchaser and must

also pay for the value of all "permanent improvements" made on the

property by the purchaser. § 40-10-122(b). "Permanent improvements"

are broadly defined by § 40-10-122(d) to include "all repairs,

improvements, and equipment attached to the property as fixtures."

Second, if the property contains a residential structure, the redemptioner

must pay certain insurance premiums associated with the property paid

by the purchaser and must also pay for the value of all "preservation

improvements" made on the property by the purchaser. § 40-10-122(c).

5 SC-2022-0653

"Preservation improvements" are defined as "improvements made to

preserve the property by properly keeping it in repair for its proper and

reasonable use, having due regard for the kind and character of the

property at the time of sale." § 40-10-122(d).

The parties agree that this case is governed by § 40-10-122(c). They

disagree, however, as to the meaning of the term "preservation

improvements." When construing statutory language, the following

principles are applicable:

" ' " '[I]t is this Court's responsibility in a case involving statutory construction to give effect to the legislature's intent in enacting a statute when that intent is manifested in the wording of the statute …. " ' " '[I]f the language of the statute is unambiguous, then there is no room for judicial construction and the clearly expressed intent of the legislature must be given effect.' " ' " … In determining the intent of the legislature, we must examine the statute as a whole and, if possible, give effect to each section.'

6 SC-2022-0653

" ' " Ex parte Exxon Mobil Corp., 926 So. 2d 303, 309 (Ala. 2005).

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Ex parte J.C. King III PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CIVIL APPEALS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-jc-king-iii-petition-for-writ-of-certiorari-to-the-court-of-ala-2023.