GIERKE, Justice.
Edward H. Steffes, Steffes Farm Group, Adolph Henke, and Frances Henke [collectively referred to as Steffes] appeal from a partial summary judgment quieting title to certain tax-forfeited land in Lowell D. Reg-stad and R.A. Kost [collectively referred to as Regstad]. We affirm.
Steffes is the former owner of lots in Fargo to which Cass County acquired title by tax deeds. In a letter dated January 28, 1987, Cass County informed Fargo:
“You may purchase these lots for $1.00 per lot. Please send a letter authorizing us to cancel all special assessments on the property if you do wish to purchase these lots....
“There will be a 30-day waiting period before we can issue you a deed as the County Auditor is required to give notice to the former owner.”
In a letter dated February 18, 1987, Fargo informed Cass County that it, wished to purchase the lots, to “[p]lease cancel all 1986 and prior year special assessments” on the parcels, and that “[w]e have sent a check for $592.00 to the County Treasurer for the $1.00 purchase price plus $7.00 recording fee for each parcel.” The Cass County Auditor then notified Steffes of a 30-day period within which to redeem by paying the delinquent taxes, penalties, and interest. Steffes did not redeem.
County deeds to the lots were received by Fargo and were recorded between March 26 and April 7,1987. Fargo publicly advertised the lots for sale on April 26 and 29 and requested sealed proposals by May 4, 1987. Regstad subsequently purchased the lots from Fargo for $63,500 and received a quitclaim deed to the property on May 18, 1987.
Regstad then sued Steffes to quiet title to the property. Steffes answered the complaint and filed a third-party complaint against Fargo and Cass County for damages if Regstad succeeded in the quiet title action. Fargo and Cass County answered the third-party complaint and Fargo counterclaimed against Steffes seeking indemni
fication for damages resulting from nonpayment of the special assessments.
The trial court granted Regstad’s motion for summary judgment quieting title to the property in Regstad; granted summary judgment in favor of Fargo and Cass County on the third-party action; and denied Steffes’ motion for summary judgment on Fargo’s counterclaim, concluding that there were genuine issues as to material facts. We dismissed the first appeal which followed entry of the partial summary judgment because Fargo’s counterclaim against Steffes remained pending and no order comporting with Rule 54(b), N.D.R.Civ.P., had been entered.
See Regstad v. Steffes,
433 N.W.2d 202 (N.D.1988). After the appeal was dismissed, Regstad sought a Rule 54(b) order from the trial court. Following a hearing on the motion, the trial court determined that there was no just reason for delay and certified the partial summary judgment as a final judgment. Steffes now appeals from the partial summary judgment.
Steffes essentially asserts that defects occurred in the tax-forfeiture process through which Fargo obtained title to the property. Steffes has raised a number of issues regarding the interpretation of §§ 57-28-17,
57-28-18,
57-28-19,
and 57-28-19.1,
N.D.C.C., which deal with the
disposition of tax-forfeited land acquired by a county.
Regstad initially contends that Steffes does not have standing to challenge Regstad’s title to the property. However, as the former owner of tax-forfeited property, Steffes has standing to challenge a tax-based title by asserting a statutory right to redeem or repurchase the property.
Duchscherer v. Aanerud,
216 N.W.2d 279, 281-282 (N.D.1974);
Remmich v. Wagner,
77 N.D. 120, 41 N.W.2d 170, 174 (1950).
Regstad asserts, and the trial court held, that even if Cass County’s sale of the property to Fargo were defective, Regstad is entitled to summary judgment under the marketable record title provisions of § 57-28-19.1 because the county deeds were recorded, Fargo entered into possession, and no lis pendens was recorded within three months of the city entering into possession of the property. Although Fargo did not show possession of record by affidavit or possess the property for three months before selling it to Regstad, the trial court concluded that the city “showed possession when the deeds were filed and further evidenced possession by the announcements of sale,” and that § 57-28-19.1 did not impose a three-month-possession requirement. We disagree with the trial court’s interpretation of the statute.
Section 57-28-19.1 is patently ambiguous. We believe, however, that it must be construed to impose a requirement that the city possess real property purchased pursuant to § 57-28-17 or § 57-28-19 for a period of three months before it may be deemed to have marketable record title. The statute deals with “marketable
record
title.” [Emphasis added]. Thus, a city’s entry into possession must be shown of record, which requires the recording of a document indicating entry into possession. The statute provides that “the fact of possession by the city may be shown of record by one or more affidavits which ... show that the city entered into possession of the property and continued such possession for three months or longer.” To construe the statute without a three-month-possession requirement would render the words “continued such possession for three months or longer” ineffective surplusage. There is a presumption that “[t]he entire statute is intended to be effective.” Section 1-02-38, N.D.C.C. As we said in
County of Stutsman v. State Historical Society,
371 N.W.2d 321, 325 (N.D.1985):
“All sections of a statute must be construed to have meaning because the law neither does nor requires idle acts. Section 31-11-05(23), N.D.C.C.;
State v. Nordquist,
309 N.W.2d 109 (N.D.1981). In short, we are guided by the commonsense principle that a statute is to be read to give effect to each of its provisions, whenever fairly possible.”
We therefore conclude that for a city to have marketable record title to real estate purchased pursuant to § 57-28-17 or § 57-28-19, the county deed conveying the property must be recorded, the city must enter into possession of the property and continue such possession for three months or longer, and there must be no lis pendens recorded within three months of the date on which the city entered possession.
Although we believe the trial court erroneously interpreted § 57-28-19.1, the partial summary judgment is nevertheless sustainable because the trial court correctly determined that, as a matter of law, Steffes had no right to repurchase the property.
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GIERKE, Justice.
Edward H. Steffes, Steffes Farm Group, Adolph Henke, and Frances Henke [collectively referred to as Steffes] appeal from a partial summary judgment quieting title to certain tax-forfeited land in Lowell D. Reg-stad and R.A. Kost [collectively referred to as Regstad]. We affirm.
Steffes is the former owner of lots in Fargo to which Cass County acquired title by tax deeds. In a letter dated January 28, 1987, Cass County informed Fargo:
“You may purchase these lots for $1.00 per lot. Please send a letter authorizing us to cancel all special assessments on the property if you do wish to purchase these lots....
“There will be a 30-day waiting period before we can issue you a deed as the County Auditor is required to give notice to the former owner.”
In a letter dated February 18, 1987, Fargo informed Cass County that it, wished to purchase the lots, to “[p]lease cancel all 1986 and prior year special assessments” on the parcels, and that “[w]e have sent a check for $592.00 to the County Treasurer for the $1.00 purchase price plus $7.00 recording fee for each parcel.” The Cass County Auditor then notified Steffes of a 30-day period within which to redeem by paying the delinquent taxes, penalties, and interest. Steffes did not redeem.
County deeds to the lots were received by Fargo and were recorded between March 26 and April 7,1987. Fargo publicly advertised the lots for sale on April 26 and 29 and requested sealed proposals by May 4, 1987. Regstad subsequently purchased the lots from Fargo for $63,500 and received a quitclaim deed to the property on May 18, 1987.
Regstad then sued Steffes to quiet title to the property. Steffes answered the complaint and filed a third-party complaint against Fargo and Cass County for damages if Regstad succeeded in the quiet title action. Fargo and Cass County answered the third-party complaint and Fargo counterclaimed against Steffes seeking indemni
fication for damages resulting from nonpayment of the special assessments.
The trial court granted Regstad’s motion for summary judgment quieting title to the property in Regstad; granted summary judgment in favor of Fargo and Cass County on the third-party action; and denied Steffes’ motion for summary judgment on Fargo’s counterclaim, concluding that there were genuine issues as to material facts. We dismissed the first appeal which followed entry of the partial summary judgment because Fargo’s counterclaim against Steffes remained pending and no order comporting with Rule 54(b), N.D.R.Civ.P., had been entered.
See Regstad v. Steffes,
433 N.W.2d 202 (N.D.1988). After the appeal was dismissed, Regstad sought a Rule 54(b) order from the trial court. Following a hearing on the motion, the trial court determined that there was no just reason for delay and certified the partial summary judgment as a final judgment. Steffes now appeals from the partial summary judgment.
Steffes essentially asserts that defects occurred in the tax-forfeiture process through which Fargo obtained title to the property. Steffes has raised a number of issues regarding the interpretation of §§ 57-28-17,
57-28-18,
57-28-19,
and 57-28-19.1,
N.D.C.C., which deal with the
disposition of tax-forfeited land acquired by a county.
Regstad initially contends that Steffes does not have standing to challenge Regstad’s title to the property. However, as the former owner of tax-forfeited property, Steffes has standing to challenge a tax-based title by asserting a statutory right to redeem or repurchase the property.
Duchscherer v. Aanerud,
216 N.W.2d 279, 281-282 (N.D.1974);
Remmich v. Wagner,
77 N.D. 120, 41 N.W.2d 170, 174 (1950).
Regstad asserts, and the trial court held, that even if Cass County’s sale of the property to Fargo were defective, Regstad is entitled to summary judgment under the marketable record title provisions of § 57-28-19.1 because the county deeds were recorded, Fargo entered into possession, and no lis pendens was recorded within three months of the city entering into possession of the property. Although Fargo did not show possession of record by affidavit or possess the property for three months before selling it to Regstad, the trial court concluded that the city “showed possession when the deeds were filed and further evidenced possession by the announcements of sale,” and that § 57-28-19.1 did not impose a three-month-possession requirement. We disagree with the trial court’s interpretation of the statute.
Section 57-28-19.1 is patently ambiguous. We believe, however, that it must be construed to impose a requirement that the city possess real property purchased pursuant to § 57-28-17 or § 57-28-19 for a period of three months before it may be deemed to have marketable record title. The statute deals with “marketable
record
title.” [Emphasis added]. Thus, a city’s entry into possession must be shown of record, which requires the recording of a document indicating entry into possession. The statute provides that “the fact of possession by the city may be shown of record by one or more affidavits which ... show that the city entered into possession of the property and continued such possession for three months or longer.” To construe the statute without a three-month-possession requirement would render the words “continued such possession for three months or longer” ineffective surplusage. There is a presumption that “[t]he entire statute is intended to be effective.” Section 1-02-38, N.D.C.C. As we said in
County of Stutsman v. State Historical Society,
371 N.W.2d 321, 325 (N.D.1985):
“All sections of a statute must be construed to have meaning because the law neither does nor requires idle acts. Section 31-11-05(23), N.D.C.C.;
State v. Nordquist,
309 N.W.2d 109 (N.D.1981). In short, we are guided by the commonsense principle that a statute is to be read to give effect to each of its provisions, whenever fairly possible.”
We therefore conclude that for a city to have marketable record title to real estate purchased pursuant to § 57-28-17 or § 57-28-19, the county deed conveying the property must be recorded, the city must enter into possession of the property and continue such possession for three months or longer, and there must be no lis pendens recorded within three months of the date on which the city entered possession.
Although we believe the trial court erroneously interpreted § 57-28-19.1, the partial summary judgment is nevertheless sustainable because the trial court correctly determined that, as a matter of law, Steffes had no right to repurchase the property.
In its memorandum opinion, the trial court determined that the former owner of tax-forfeited real estate subject to special assessment liens sold under § 57-28-17, N.D.C.C., has no redemption or repurchase rights:
“The Court must first determine whether the sale was pursuant to either Section 57-28-17 or 57-28-19. In this case the real estate was subject to a special assessment lien for improvements made by the city. Section 58[sic] — 28—17 provides that:
“Notwithstanding the provisions of this section or other provisions of law, any such parcel of real estate that is subject to a special assessment lien for improvements made by a city may be sold between annual sales by the county Auditor for cash to the city at whatever price less than the minimum sales price that is agreed upon by the board of county commissioners and the governing body of the city.
“Because the real estate in question was subject to a special assessment lien this section applies and not section 57-28-19 NDCC. Pursuant to section 57-28-17 NDCC Defendants had no right to repurchase beyond their redemption rights which had expired prior to the time of sale to the city.”
Relying on § 1-02-07, N.D.C.C., Reg-stad, Cass County and Fargo argue that § 57-28-17 is a special provision relating to dispositions of real estate subject to special assessments and must prevail over the general provisions of §§ 57-28-18 and 57-28-19. We agree.
Section 57-28-17, N.D.C.C., specifically provides that the sale by the county to the city may be “at whatever price ... agreed upon” between the county and the city, “notwithstanding the provisions of this section or other provisions of law.” Words used in a statute are to be understood in their ordinary sense, unless a contrary intention plainly appears. Section 1-02-02, N.D.C.C.;
Wills v. Schroeder Aviation, Inc.,
390 N.W.2d 544, 545 (N.D.1986). The word “notwithstanding,” which begins the statutory clause, connotes opposition to, and not compatibility with, other statutes.
See Theodore Roosevelt Agency v. General Motors Acceptance Corp.,
156 Colo. 237, 398 P.2d 965, 966 (1965). The phrase “notwithstanding ... other provisions of law” makes the rules embodied in the statute “sui generis” and controlling over other statutory law.
See Dover v. Dover,
15 Cal.App.3d 675, 93 Cal.Rptr. 384, 385 n. 3 (1971);
Board of Education v. Maple Heights Teachers Ass’n,
41 Ohio Misc. 27, 322 N.E.2d 154, 157 (1973). This specific language in the statute thus renders the general provisions of §§ 57-28-18 and 57-28-19, N.D.C.C., inapplicable to sales conducted under § 57-28-17, N.D.C.C. Therefore, we conclude that the trial court did not err in determining as a matter of law that Steffes had no right to repurchase the property.
Our' conclusion that Steffes has no repurchase rights renders it unnecessary to address the other issues raised by the parties. Accordingly, the judgment is affirmed.
ERICKSTAD, C.J., and VANDE WALLE, MESCHKE and LEVINE, JJ., concur.