TDGA, LLC. v. CBIRA, LLC et al.Annotate this Case
TDGA, LLC acquired a certain piece of property from another entity that had purchased the property at a tax sale. Afterwards, TDGA followed the non-judicial process of foreclosing any right of redemption to the property in accordance with Georgia law. TDGA provided notice of the foreclosure of redemption rights to all interested parties in the property, including the Georgia Department of Revenue and the Georgia Department of Labor (Departments), each of which held recorded tax liens against the property. Following the completion of this procedure, which the Departments did not contest, TDGA filed the current quiet title action at issue in this appeal. This case presented a question of whether conventional actions for quiet title, where the State of Georgia asserts an interest in the property at issue, were barred by the doctrine of sovereign immunity. The Supreme Court found that they were barred, and affirmed the ruling of the trial court. The Court found further, that in rem actions for quiet title were not barred by sovereign immunity.