Sainer v. County Treasurer of Warren County, 33 N.Y.2d 271 (1973)

A tax deed describing property with three boundaries and the area is sufficient if the fourth boundary can be mathematically and geographically determined without unreasonable or arbitrary results.

Summary

This case concerns the validity of tax deeds where the property description included only three boundaries and the area. Warren County sold a portion of Sainer’s land for unpaid taxes to the defendant, describing it as six-eighths of an acre bounded on the east by Lake George and on the north and south by specified lines. Sainer challenged the deeds, arguing the description was insufficient. The trial court agreed, but the Appellate Division reversed, finding the description adequate since the fourth boundary could be determined. The Court of Appeals affirmed, holding the description sufficient and rejecting the need for a “unitary parcel” rule, emphasizing the importance of efficient tax collection.

Facts

Sainer owned seven-eighths of an acre on Lake George. Warren County sold six-eighths of an acre of this parcel to the defendant at a tax sale for unpaid property taxes. The tax deeds described the parcel as bounded on the east by Lake George, and on the north and south by specified lines, but did not specify a western boundary. The defendant paid the taxes and made improvements on the property. Sainer sued to invalidate the tax deeds, claiming the property description was insufficient.

Procedural History

The trial court ruled in favor of Sainer, holding the tax deeds void due to the uncertain description. The Appellate Division reversed, upholding the validity of the deeds. Sainer appealed to the New York Court of Appeals.

Issue(s)

Whether a tax deed describing a parcel of land with three boundaries and its area is void for uncertainty if the fourth boundary can be mathematically calculated.

Holding

Yes, because the lack of a specified fourth boundary does not invalidate the deed if it can be determined through mathematical calculation and surveying without leading to an unreasonable or arbitrary result.

Court’s Reasoning

The Court of Appeals reasoned that the description was sufficient because the fourth boundary could be determined mathematically and through surveying. The court stated that the fixation of the fourth boundary line is “purely a mathematical and surveying problem, readily solvable.” The court dismissed concerns that the County Treasurer might act unreasonably in designating the boundary. The court emphasized that the primary concern of the statute is the collection of delinquent taxes and the marketability of the taxed parcels should not be unduly impaired. The court found no need for a “unitary” subparcel rule of construction, which might impede speedy tax sales. The Court referenced Godfrey, Enforcement of Delinquent Property Taxes in New York, 24 Albany L. Rev. 271, 282, n. 31, to support their argument that the bidding should relate not only to the amount of the delinquent taxes but to the portion of the taxed parcel which the bidder seeks to buy. The court stated: “Absent such a showing, the county treasurer had no duty to sell less than all of the taxed property. Nevertheless, when he found that he was able to satisfy the tax lien by selling less than the whole property, he was not only authorized but required by the statute, in reason, to accept such a bid.”