Real Property—Tax Deeds—Actions to Quiet Title

The Third District Court of Appeals voided a judgment where a purchaser of a tax deed had obtained due to their failure to include the tax collector as a necessary party to the action. See Yorty V Abreu, 33Fla. L. Weekly D1931 (Fla. 3rd DCA 2008). Section 194.181(3) F.S. specifically states the tax collector must be included as a defendant.


Purchasing tax deeds is always a risky venture. You must always anticipate post purchase expenses. My suggestion is to obtain a title commitment before purchase and confirm what will be necessary to obtain clear and marketable title. Strategies might then include obtaining a quit-claim deed from the current owner and negotiation with any lien holders.

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