In Re Petition of Eaton County Treasurer for Foreclosure

CourtMichigan Court of Appeals
DecidedJanuary 13, 2026
Docket370480
StatusUnpublished

This text of In Re Petition of Eaton County Treasurer for Foreclosure (In Re Petition of Eaton County Treasurer for Foreclosure) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Petition of Eaton County Treasurer for Foreclosure, (Mich. Ct. App. 2026).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

In re PETITION OF EATON COUNTY TREASURER FOR FORECLOSURE.

EATON COUNTY TREASURER, UNPUBLISHED January 13, 2026 Petitioner-Appellee, 2:30 PM

v No. 370480 Eaton Circuit Court ANDREW ROTH, LC No. 20-000403-CZ

Respondent-Appellant.

EATON COUNTY TREASURER,

Petitioner-Appellee,

v No. 370482 Eaton Circuit Court NANCY VOGL, Personal Representative of the LC No. 21-000537-CZ ESTATE OF SALLY JOAN RANDALL, and STACIA MATHIAS, Personal Representative of the ESTATE OF RANDY MATHIAS,

Intervening Plaintiffs-Appellants.

Before: SWARTZLE, P.J., and GARRETT and WALLACE, JJ.

PER CURIAM.

-1- These consolidated appeals1 involve claims for the distribution of proceeds remaining from the tax-foreclosure sales of properties after the alleged satisfaction of delinquent property taxes, interest, penalties, and fees. In Docket No. 370480, respondent, Andrew Roth, appeals by right the circuit court order denying his motion to disburse remaining proceeds. In Docket No. 370482, intervening plaintiff Nancy Vogl, personal representative of the Estate of Sally Joan Randall (the Randall Estate), and intervening plaintiff Stacia Mathias, personal representative of the Estate of Randy Mathias (the Mathis Estate), appeal by right a separate order denying their motions to disburse remaining proceeds. For the reasons stated herein, we affirm the circuit court’s order in Docket No. 370480. In Docket No. 370482, we affirm in part, reverse in part, and remand for further proceedings consistent with this opinion.

I. STATUTORY BACKGROUND

The Michigan Supreme Court held in Rafaeli, LLC v Oakland Co, 505 Mich 429, 484; 952 NW2d 434 (2020), that former owners of properties sold via tax-foreclosure for more than what was owed in taxes, interests, penalties, and fees had “a cognizable, vested property right to the remaining proceeds resulting from the tax-foreclosure sale of their properties.” Because this right continued to exist after fee simple title to the properties vested with the foreclosing governmental unit (FGU), the FGU’s “retention and subsequent transfer of those proceeds into the county general fund amounted to a taking of plaintiffs’ properties” under the Takings Clause of Michigan’s Constitution. Id. at 484-485, citing Const 1963, art 10, § 2. Accordingly, former owners were entitled to just compensation in the form of the return of the remaining proceeds. Id. at 485. When the Court decided Rafaeli, the General Property Tax Act (GPTA), MCL 211.1 et seq., did not provide a means by which property owners could recover their remaining proceeds.

In response to Rafaeli, the Michigan Legislature passed 2020 PA 255 and 2020 PA 256, which were given immediate effect on December 22, 2020. MCL 211.78t, a provision added to the GPTA by 2020 PA 256, provides the exclusive means for former owners to claim and receive any applicable “remaining proceeds”2 from the tax-foreclosure sales of their former properties. This Court held in In re Petition of Muskegon Co Treasurer for Foreclosure, 348 Mich App 678; 20 NW3d 337 (2023), that MCL 211.78t was a duly enacted statute that passed constitutional muster. Id. at 703-704.

II. RELEVANT FACTS AND PROCEEDINGS

In Docket No. 370480, the circuit court entered a judgment of foreclosure against respondent’s property on February 17, 2021, effective March 31, 2021. It was undisputed that respondent did not file Form 5743 pursuant to MCL 211.78t(2) to notify petitioner of respondent’s intent to claim an interest in any remaining proceeds until February 2022, well beyond the statute’s July 1, 2021 deadline. Respondent moved in the circuit court for the disbursement of remaining

1 In re Petition of Eaton Co Treasurer for Foreclosure, unpublished order of the Court of Appeals, entered October 7, 2024 (Docket Nos. 370480 and 370482). 2 Rafaeli refers to “surplus proceeds,” whereas MCL 211.78t refers to “remaining proceeds.” We will use these terms interchangeably.

-2- proceeds. Petitioner opposed the motion on the basis that respondent failed to file Form 5743 by the statutory deadline. Following a hearing on respondent’s motion, the circuit court denied the motion on the basis that respondent had not complied with MCL 211.78t’s applicable notice requirement.

In Docket No. 370482, Sally Joan Randall owned property in Eaton County when she died in 2020. Nancy Vogl, Sally’s daughter and personal representative of the Randall Estate, contacted petitioner and told him that she and her brother wanted to give the property to the county. Petitioner informed her that the county could not simply accept property and that the property would have to go through the foreclosure process. A judgment of foreclosure entered against the property on February 16, 2022. Three months later, petitioner and Delta Township, where the property was located, entered into a consent agreement for demolition because the condition of the structure on the property rendered it a public nuisance and a hazard to public health, safety, and welfare. The demolition order provided that petitioner or subsequent holders of title to the property, or both, would demolish all structures on the property because they were hazardous to public safety. Petitioner obtained an estimate from a company indicating that demolition would cost $81,926.63. This amount was added to the minimum bid. At the October 2022 tax-foreclosure auction, a buyer paid $83,105: $1,179 for the property and $81,926.63 as a “guaranty” to ensure compliance with the demolition order.3 Once the buyer demolished the hazardous structure, petitioner refunded his $81,926.63 by check.

Petitioner sent the Randall Estate notice under MCL 211.78t(3) stating that there were no remaining proceeds to distribute because the $1,179 sales price for the property was well below the minimum bid. Instead of remaining proceeds, there was a deficit of $13,899.99. Notwithstanding this notice, the Randall Estate moved the circuit court to disburse remaining proceeds of $63,292.71. The Randall Estate argued that the property sold for $83,105, all of which petitioner was required by MCL 211.78m(8) to place in a restricted account and pay in accordance with the priorities listed in that statute. The top three priorities, in order, were the county where the property was located, the FGU, and the Randall Estate. The Randall Estate contended that the $83,105 sales price, minus unpaid taxes, interests, penalties, and fees, and minus petitioner’s 5% sales commission left remaining proceeds of $63,292.71. At the hearing on the Randall Estate’s motion to disburse remaining proceeds, petitioner explained the circumstances surrounding the demolition order, the estimated cost of demolition, the property buyer’s $81,926.63 guaranty, the buyer’s satisfaction of the demolition order, and petitioner’s return of the guaranty to the buyer. The circuit court rejected the Randall Estate’s argument, adopted petitioner’s reasoning, and denied the estate’s motion to disburse remaining proceeds.

Also in Docket No. 370482, a judgment of foreclosure was entered against property owned by decedent Randy Mathias on February 11, 2021, effective March 31, 2021. The Mathias Estate property sold at a tax-foreclosure auction for $6,723. After deducting the property’s unpaid taxes,

3 We note that petitioner attempted to sell the property at auction the previous month, with the requisite amount of the minimum bid being $15,020.04 (that reserve price also included the above- referenced guaranty in the amount of $81,926.63). However, the property did not sell in the first auction.

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Cite This Page — Counsel Stack

Bluebook (online)
In Re Petition of Eaton County Treasurer for Foreclosure, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-petition-of-eaton-county-treasurer-for-foreclosure-michctapp-2026.