Hamilton County and F/U/B of the State of Tennessee v. Tax Year 2018 Delinquent Taxpayers

CourtCourt of Appeals of Tennessee
DecidedDecember 17, 2024
DocketE2024-00581-COA-R3-CV
StatusPublished

This text of Hamilton County and F/U/B of the State of Tennessee v. Tax Year 2018 Delinquent Taxpayers (Hamilton County and F/U/B of the State of Tennessee v. Tax Year 2018 Delinquent Taxpayers) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hamilton County and F/U/B of the State of Tennessee v. Tax Year 2018 Delinquent Taxpayers, (Tenn. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF TENNESSEE 12/17/2024

AT KNOXVILLE Assigned on Briefs October 1, 2024

HAMILTON COUNTY AND F/U/B OF THE STATE OF TENNESSEE ET AL. v. TAX YEAR 2018 DELINQUENT TAXPAYERS ET AL.

Appeal from the Chancery Court for Hamilton County No. 11244 Pamela A Fleenor, Chancellor ___________________________________

No. E2024-00581-COA-R3-CV ___________________________________

This appeal arises from an action to recover excess proceeds from the tax sale of a parcel of real property. After the redemption period had ended, the appellants, heirs to the decedent whose property was sold at the tax sale, moved to claim the excess proceeds pursuant to Tennessee Code Annotated § 67-5-2702. The appellee, a company that had held a valid judgment lien against the real property at the time of the tax sale, also moved to claim the excess proceeds, arguing that its lien held priority over the heirs’ claim pursuant to § 67-5-2702(c)(2). The heirs objected, asserting that because the company had allowed its judgment lien to lapse after the tax sale, the company no longer maintained priority to claim the excess proceeds from that sale. The trial court granted the company’s motion, determining that because its judgment lien had been valid and enforceable at the time of the tax sale, the company maintained priority over the heirs to receive the excess proceeds pursuant to § 67-5-2702(c)(2). Discerning no reversible error, we affirm.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Chancery Court Affirmed; Case Remanded

THOMAS R. FRIERSON, II, J., delivered the opinion of the court, in which ANDY D. BENNETT and KENNY ARMSTRONG, JJ., joined.

Darren W. Kennedy, Chattanooga, Tennessee, for the appellants, Billie Friddell, Earl Greer, and Peggy Talley.

Charles D. Waller and Hannah M. Clyde, Knoxville, Tennessee, for the appellee, Ford Motor Credit Company, LLC. OPINION

1. Factual and Procedural Background

The determinative facts surrounding the underlying tax action are undisputed. In 1980, Wilma Greer and Louise Meroney acquired, by warranty deed, a fee simple interest in certain unimproved real property located on Bennett Road in Chattanooga, Tennessee (“the Property”). The deed was properly recorded in the register’s office of Hamilton County, Tennessee. On February 10, 2003, Ford Motor Credit Company, LLC (“FMCC”) obtained a default judgment against Ms. Greer in the amount of $7,606.58 and recorded the judgment in the register’s office for Hamilton County on June 3, 2003, thus perfecting a judgment lien in favor of FMCC against any real property owned by Ms. Greer. See Tenn. Code Ann. § 25-5-101(b)(1) (West July 1, 2005, to current) (“[J]udgments and decrees . . . in excess of five hundred dollars ($500) obtained from and after July 1, 1969, in any court of general sessions of this state shall be liens upon the debtor’s land from the time a certified copy of the judgment or decree shall be registered in the lien book in the register’s office of the county where the land is located.”).

Ms. Meroney died in 2012, leaving Ms. Greer as sole owner of the Property. FMCC timely sought and obtained an order from the trial court “reviving and extending” its judgment against Ms. Greer for an additional ten years—from February 11, 2013, to February 11, 2023. This was in accordance with Tennessee Rule of Civil Procedure 69.04, which governs the procedure for obtaining an extension of a previously awarded judgment and provides: “Within ten years from the entry of a judgment, the creditor whose judgment remains unsatisfied may file a motion to extend the judgment for another ten years.” FMCC duly recorded the order reviving and extending its judgment on April 10, 2013, thus perfecting its extended judgment lien against the Property. See Tenn. Code Ann. § 25-5- 101(b)(1). On November 14, 2017, Ms. Greer passed away, leaving the appellants, Billie J. Friddell, Earl Greer, and Peggy Talley (“the Heirs”), as heirs and devisees under her will.

In 2022, the Property was sold through a delinquent tax sale initiated by Hamilton County, and the order confirming the sale was entered by the trial court on July 1, 2022. In February 2023, FMCC’s ten-year judgment lien against Ms. Greer expired because FMCC had not filed a motion to extend it a second time pursuant to Rule 69.04. In early 2024, the Heirs each filed a separate motion to claim the excess proceeds from the tax sale pursuant to Tennessee Code Annotated § 67-5-2702.1 On January 25, 2024, FMCC in turn filed its motion to claim excess proceeds from the tax sale of the Property, claiming that (1) the judgment it had acquired against Ms. Greer in 2003 had never been satisfied; (2) interest had continued to accrue regarding the judgment over the years; and (3) as of July 1, 2022, the date of the order confirming the tax sale of the Property, the amount due by

1 Billie Friddell’s motion was filed on January 18, 2024, Earl Greer’s motion was filed on January 22, 2024, and Peggy Talley’s motion was filed on March 21, 2024. -2- reason of the then-valid judgment lien was $19,252.50.

The Heirs filed an objection to FMCC’s motion, arguing that although FMCC had held a valid lien encumbering the Property at the time of the tax sale in July 2022, FMCC had lost its priority to claim any excess proceeds. They postulated that FMCC had allowed its judgment lien against the Property to lapse in February 2023, prior to the company’s taking any action to collect on the judgment lien pursuant to § 67-5-2702.

After a hearing conducted on February 19, 2024, the trial court entered an order granting FMCC’s motion to claim excess proceeds in the amount of $19,252.50. The court reasoned that the outcome of the case turned on the interpretation of and interplay between two relevant statutes: the statute governing distribution of excess proceeds from tax sales, § 67-5-2702, and the statute governing the period during which a judgment lien is valid, Tennessee Code Annotated § 25-5-105. The court determined that because both provisions applied to the instant action, the more specific statute governing tax sales should control.

The trial court then focused on § 67-5-2702(c), the portion of the statute delineating the order of priority in which valid claims for excess tax sale proceeds should be paid. The trial court concluded that FMCC, as a “lienholder holding a lien at the time of the tax sale,” had established priority over the Heirs to receive disbursement of the excess sale proceeds. See Tenn. Code Ann. § 67-5-2702(c)(2). The trial court interpreted the plain meaning of the statutory phrase, “at the time of the tax sale,” to mean that because FMCC had held a valid judgment lien in July 2022, when the order confirming the tax sale was entered, the company was entitled to excess proceeds from the sale even though its judgment lien had since expired. The Heirs timely appealed.

II. Issue Presented

The Heirs present the following issue for review, which we have restated slightly:

Whether Tennessee Code Annotated § 67-5-2702 requires a judgment lien creditor seeking excess proceeds from a tax sale of real property to hold a valid, unexpired judgment lien at the time the creditor files its motion for excess proceeds, or whether it is sufficient for the creditor to maintain a valid lien at the time of the tax sale.

III. Standard of Review

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Hamilton County and F/U/B of the State of Tennessee v. Tax Year 2018 Delinquent Taxpayers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hamilton-county-and-fub-of-the-state-of-tennessee-v-tax-year-2018-tennctapp-2024.