Crowe v. Savvy IN, LLC
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The Supreme Court affirmed the judgment of the trial court denying the Indiana Trial Rule 60(B)(6) motion filed by James and Phyllis Crowe seeking relief from the judgment of the trial court granting Savvy IN, LLC's petition to issue tax deeds for certain properties, holding that Savvy IN's certified and first-class mailed notice letters notifying the Crowes that Savvy IN purchased their properties at a tax sale satisfied the minimum requirements under the Fourteenth Amendment's Due Process Clause and Indiana law.
In 2019, the Crowes received notice that their properties were sold in a tax sale due to their failure to pay 2018 property taxes. Savvy IN purchased the properties at a tax sale. When the Crowes passed the deadline to redeem the properties Savvy IN petitioned the trial court to direct the county auditor to issue tax deeds for the properties. The trial court granted the motion. The Crowes moved for relief from the judgment under Rule 60(B)(6) on the grounds that they did not receive notice letters, thus rendering the judgment and tax deeds void. The trial court denied the motion. The Supreme Court affirmed, holding that Savvy IN was entitled to the tax deeds issued by the trial court because the mailed notices satisfied the constitutional and statutory requirements.
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