Delta Property Management v. Profile Investments, Inc.

Summary

The court held that the law-of-the-case doctrine did not bar consideration of whether the clerk had additional notice obligations after certified-mail notice was returned undeliverable because that issue had not previously been decided. Applying due-process principles, the court held that the clerk was required to take additional reasonable steps to notify Delta before the tax sale, and that the failure to do so invalidated the tax deed. The court quashed the district court's decision and remanded with instructions to affirm summary judgment for Delta.