In re Application of the County Collector (Blossom63) (2022)
Citation: 2022 IL 126929 · Court: Supreme Court of Illinois, No. 126929 · Decided: 2022
An illinois tax-deed notice decision: a tax-deed applicant strictly complied with the 35 ILCS 200/22-5 “take notice” by listing the delinquent tax year for which the sale was held, and was not required to also list the additional later tax years it paid to complete the sale.
Facts
GAN purchased a Cook County property at the 2016 annual tax sale for the 2014 delinquent tax year, then assigned its interest to Blossom63 Enterprises, LLC. Blossom63 served the statutory 22-5 “take notice.” Devonshire, LLC sought to intervene and moved to vacate Blossom63’s tax deed, contending the take-notice failed to strictly comply with 35 ILCS 200/22-5 because it did not list all of the delinquent tax years (including later years Blossom63 had paid to complete the sale). The circuit court vacated the deed; the appellate court reversed; the case reached the Illinois Supreme Court.
Holding
The Illinois Supreme Court affirmed the appellate court, holding that Blossom63 strictly complied with 35 ILCS 200/22-5 by listing the delinquent tax year for which the sale was held; it was not required to additionally list the later delinquent tax years it paid to complete the sale. The take-notice was adequate and the tax deed stood.
Reasoning
- Strict compliance defined by statutory text. Section 22-5 requires the take-notice to identify the tax year(s) for which the property was sold; the year of the sale is the operative datum. The Court read the requirement against the statute’s text rather than expanding it to every subsequently paid year.
- Notice still served its purpose. Listing the sale year gave the owner the information needed to understand the proceeding and exercise the right-of-redemption; omitting later paid years did not undermine that purpose.
- No deed-defeating defect. Because the notice strictly complied, the circuit court erred in vacating the deed.
Practical impact
- For Illinois tax-buyers, Blossom63 clarifies the content required in a 22-5 take-notice — reducing the risk that a deed is vacated for omitting later-paid tax years — while reaffirming that strict compliance with the listed requirements remains mandatory.
- For owners and redemption claimants, it narrows one avenue (the “you didn’t list every year” theory) for attacking a tax deed, though other strict-compliance defects in the take-notice remain available.
- It is a key data point in Illinois’s broader, post-tyler-v-hennepin-county reckoning over tax-sale procedure and equity (see also bell-v-pappas-2025).
Good-law status
Still good law. Decided 2022; not overruled as of last_verified 2026-06-02.
Why it matters
It sets the content standard for the Illinois 22-5 take notice — the single most litigated procedural step between a tax sale and a tax deed — and confirms that strict compliance is measured against the statute’s actual text.
Related authorities
- bell-v-pappas-2025 — Cook County tax-sale equity-forfeiture held unconstitutional.
- tyler-v-hennepin-county — surplus-equity retention is a taking.
- mennonite-v-adams · mullane-v-central-hanover — tax-sale notice baselines.
Applies in →
illinois (state law). Persuasive elsewhere on take-notice strict-compliance content.
Legal information, not legal advice. This page summarizes a court decision for educational purposes and does not create an attorney-client relationship. Verify against the primary opinion and consult a licensed attorney in the relevant jurisdiction before acting. Last verified 2026-06-02.