Good-Faith Purchaser (Bona Fide Purchaser) Doctrine in Tax Sales and Foreclosure
Cross-jurisdiction doctrine page. Legal information, not legal advice. Last verified: 2026-06-10.
What it is
The good-faith purchaser doctrine — also called the bona fide purchaser (BFP) or bona fide purchaser for value without notice rule — is a common-law and statutory principle that protects a buyer who acquires property (or a lien interest) for value, in good faith, and without actual or constructive notice of any prior competing claim or defect in the seller’s title. In the tax-sale and foreclosure context the doctrine answers a critical operational question: when a sale later turns out to be defective, does the buyer keep the property or lose it?
Three elements are universally required. The buyer must:
- Pay value — some form of consideration (money, assumption of debt, etc.). The amount need not equal fair-market value; even a fraction of market price is ordinarily sufficient, though a grossly inadequate price is a warning sign courts examine for bad faith. (In re George, N.C. Sup. Ct. 2021, discussed below.)
- Act in good faith — honestly and without knowledge of adverse facts that would prompt a reasonable person to investigate further.
- Lack notice — neither actual notice (subjective knowledge of the defect) nor constructive notice (the defect would have been revealed by a reasonable title search of the recorded chain of title).
When all three are satisfied the BFP generally takes free of the defect — but only if the underlying instrument is voidable, not void. The void/voidable distinction is the most important limit on the doctrine and is addressed fully in void-vs-voidable.
The governing framework
Common-law foundation
The BFP rule is one of the oldest doctrines in Anglo-American property law. Its rationale is market liquidity: if a third-party buyer could never safely rely on a recorded deed, secondary transactions would stall. The doctrine is discussed in Restatement (Third) of Property: Mortgages and codified, with variations, in every state’s recording act and in many tax-sale statutes.
At common law, the rule operates as follows:
A voidable deed or conveyance is valid and enforceable as against the grantor and all persons with notice, but may be rescinded by the aggrieved party. A subsequent bona fide purchaser who takes the voidable instrument for value, in good faith, and without notice acquires good title and cuts off the prior party’s right to rescind. (JRank Law: Personal Property — Bona Fide Purchasers, https://law.jrank.org/pages/9188/Personal-Property-Bona-Fide-Purchasers.html, retrieved 2026-06-02.)
The inverse rule is equally firm: a void deed conveys no title, and no good-faith purchaser can acquire what was never conveyed. Because a void transaction is a nullity from inception, there is nothing in the chain of title for the BFP to rely on. (LII, Cornell: https://www.law.cornell.edu/wex/bona_fide_purchaser, retrieved 2026-06-10.)
Recording acts and the BFP
State recording acts interact with the BFP rule to determine priority between competing claimants. There are three types:
| Type | Rule | Representative states |
|---|---|---|
| Pure race | First to record wins, regardless of notice | North Carolina, Delaware, Louisiana |
| Pure notice | Subsequent BFP without notice wins over prior unrecorded interest | Connecticut, Iowa, many others |
| Race-notice | Subsequent BFP without notice AND who records first wins | California, Florida, New York, majority of states |
In pure-race states such as North Carolina, notice plays no role in the recording-act analysis — only the race to the courthouse matters. However, the BFP concept still functions independently in determining whether a judicial-sale buyer qualifies for statutory protection (e.g., G.S. 1-108), because that protection asks about good faith at the time of purchase, not about recording priority. (Source: North Carolina’s Real Estate Recording Laws, NCCU Law Review, https://archives.law.nccu.edu/cgi/viewcontent.cgi?article=1588&context=ncclr, retrieved 2026-06-10; King Law Offices: NC Pure Race Statute, https://kinglawoffices.com/civil-disputes/the-implications-of-nc-pure-race-statute-in-recording/, retrieved 2026-06-10.)
Constitutional floor: the Mullane-Jones-Mennonite line
The federal constitutional floor is relevant because it determines whether the underlying tax or foreclosure sale had any legal effect in the first place — i.e., whether the defect is the kind that renders a sale void (no BFP cure possible) or merely voidable (BFP cure available). Four Supreme Court decisions are anchor points:
- Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950): Notice must be “reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action.” Publication alone fails this standard for parties whose addresses are known. (Source: https://www.law.cornell.edu/supremecourt/text/339/306.)
- Mennonite Board of Missions v. Adams, 462 U.S. 791 (1983): Mortgagees of record are entitled to personal or mailed notice; posting and publication insufficient. (Source: https://www.law.cornell.edu/supremecourt/text/462/791.)
- Jones v. Flowers, 547 U.S. 220 (2006): When certified mail is returned unclaimed, the government must take additional reasonable steps (regular mail, door posting, “occupant” letter) before the sale may proceed. See jones-v-flowers.
- Tyler v. Hennepin County, 598 U.S. 631 (2023): Tax forfeiture that retains equity beyond the debt is an unconstitutional taking. Confirms that state law cannot override federal constitutional limits. See tyler-v-hennepin-county.
Whether a notice failure renders a sale void versus voidable — and therefore whether a BFP can take shelter in the doctrine — is a state-law question. The Court in Jones v. Flowers deliberately left the consequences of the notice failure to Arkansas on remand, illustrating that the constitutional floor and the state-law BFP consequence are analytically separate questions.
The void/voidable line: when BFP protection applies and when it does not
The relationship between the BFP doctrine and the void/voidable distinction is the most practically important analysis in this area. For the full treatment see void-vs-voidable; the summary relevant to BFP analysis is:
BFP protects against voidable defects. If the defect (procedural error, minor notice failure, technical statutory non-compliance) renders the sale voidable, a subsequent BFP who takes for value without notice acquires good title and cuts off the prior party’s ability to set aside the deed. The prior party’s remedy, if any, is monetary against the foreclosing entity.
BFP cannot protect against void defects. If the defect is so fundamental that the sale never had legal effect — because the court lacked jurisdiction, the property was tax-exempt, there was no notice whatsoever, or a constitutional minimum was not met — no amount of good faith or value paid can cure the nullity. A deed derived from a void transaction “is, in legal effect, no judgment. By it no rights are divested. From it no rights can be obtained.” (OC Interior Services, LLC v. Nationstar Mortgage, LLC, California Court of Appeal; discussed in Money and Dirt, https://moneyanddirt.com/2017/03/even-a-bona-fide-purchaser-cant-rely-on-a-void-judgment/, retrieved 2026-06-10.)
How the doctrine is codified — key state statutes
States codify BFP protection for tax-sale and foreclosure purchasers through several different mechanisms:
Judicial-sale finality statutes
North Carolina — G.S. 1-108 (the most-litigated provision in this wiki): When a judgment or order is set aside under Rule 60(b) of the N.C. Rules of Civil Procedure, G.S. 1-108 provides: “Title to property sold under such judgment to a purchaser in good faith is not thereby affected.” The effect is that a Rule 60(b) vacatur of the underlying order — even on constitutional grounds — cannot void the deed in the hands of a good-faith purchaser at the judicial or clerk-ordered sale. The ousted owner’s remedy is monetary (restitution from the foreclosing party), not restoration of the property. (Source: https://www.ncleg.net/EnactedLegislation/Statutes/HTML/BySection/Chapter_1/GS_1-108.html, retrieved 2026-06-10.)
The standard for “good faith” under G.S. 1-108 was refined in two major North Carolina cases:
- In re Foreclosure of Ackah, 804 S.E.2d 794 (N.C. Ct. App. 2017), aff’d No. 334A17 (N.C. 2018): Good-faith purchasers (the Jones family) kept title after the HOA’s notice was found defective under Rule 4 due-diligence standards. G.S. 1-108 barred title restoration; the former owner was remitted to monetary relief from the HOA. See in-re-foreclosure-of-ackah.
- In re George, No. 77A19 (N.C. Sup. Ct. Apr. 16, 2021) [In re Foreclosure of Claim of Lien filed by The Crossings Community Association]: The Supreme Court reversed the lower courts and held that the trial court abused its discretion in finding the purchasers were not good-faith purchasers. The Supreme Court held that a grossly inadequate purchase price alone cannot defeat good-faith-purchaser status; instead, courts must examine the totality of the circumstances, including whether the buyer conducted reasonable due diligence. Buyers with experience in foreclosure markets who have access to title-search tools bear a corresponding duty of affirmative diligence — they cannot “bid blindly” but should review the record for obvious service deficiencies. (Source: Justia, https://law.justia.com/cases/north-carolina/supreme-court/2021/77a19.html; NC Bankruptcy Expert analysis at https://ncbankruptcyexpert.com/2021/05/20/n-c-s-ct-in-re-george-insufficient-service-for-non-judicial-foreclosure, both retrieved 2026-06-10.)
needs_verification: The In re George Supreme Court docket number (77A19) and April 16, 2021 decision date are confirmed from multiple secondary sources. The full text of the opinion was not directly retrieved; holdings above are drawn from secondary summaries and should be verified against the primary opinion text before reliance.
Illinois — 735 ILCS 5/2-1401(e): When a judgment or order is vacated or modified under the Illinois Code of Civil Procedure § 2-1401, a bona fide subsequent purchaser who acquired rights “for value after the entry of the order or judgment but before the filing of the petition” is protected — provided that the lack of jurisdiction “does not affirmatively appear from the record proper.” The statute does not protect the purchaser where a jurisdictional defect is visible on the face of the record. (JP Morgan Chase Bank, N.A. v. Robinson, Illinois App. Ct. 2nd Dist. 2020, discussed at https://consumerfsblog.com/2020/05/illinois-app-court-2nd-dist-holds-bona-fide-foreclosure-sale-not-voided-by-latent-defect-in-service-of-process/, retrieved 2026-06-10.)
Tax-deed incontestability statutes
Many states create BFP-equivalent protection by declaring tax deeds incontestable after a fixed period or upon compliance with notice requirements:
South Carolina — S.C. Code Ann. § 12-51-160: The tax deed “must be held and taken as prima facie evidence of good title in the holder, that all proceedings have been regular and that all legal requirements have been complied with.” (Leysath v. Leysath, 209 S.C. 342, 40 S.E.2d 233 (1946).) The burden of proving defects is on the party attacking the deed. After the two-year statute of limitations in § 12-51-160 runs, “an action for the recovery of land sold pursuant to this chapter or for the recovery of the possession must not be maintained.” However, the two-year bar does not apply to jurisdictional defects, which can render the sale void at any time. The distinction between jurisdictional and non-jurisdictional failures is the core operational issue: jurisdictional defects (e.g., complete failure to provide redemption notice) void the sale and defeat BFP protection; non-jurisdictional irregularities are cured by the limitations bar. (Leysath; Charleston County Master-in-Equity analysis, https://www.charlestoncounty.gov/departments/master-in-equity/law-tax-sales.php, retrieved 2026-06-10.)
Ohio — ORC § 5721.39: Upon confirmation of sale or transfer after tax foreclosure, “the title to the parcel is incontestable in the purchaser and is free and clear of all liens and encumbrances,” with limited exceptions for federal tax liens properly filed before the proceeding and pre-existing easements and covenants. Critically, title “shall not be invalid because of any irregularity, informality, or omission of any proceedings” under the tax-foreclosure chapter, provided proper notice was given. (Source: https://codes.ohio.gov/ohio-revised-code/section-5721.39, retrieved 2026-06-10.) This is a functional equivalent of BFP protection — not framed as a “good faith” requirement but as a statutory curative provision.
Michigan — MCL 211.78l: Once a foreclosure judgment becomes effective, “all existing recorded and unrecorded interests in a property are extinguished.” Former interest holders “shall not bring an action … more than 2 years after the judgment of foreclosure.” Actions to recover proceeds are governed separately by MCL 211.78t. (Source: https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-211-78l, retrieved 2026-06-10.) Michigan title companies nonetheless commonly require 20 years or a quiet title action before insuring tax-deed titles, because the In re Wayne County, 478 Mich. 1 (2007) line of cases creates practical risk even within the statutory framework.
Non-judicial foreclosure / trustee’s sale statutes
California — Civil Code § 2924h: A trustee’s sale is final upon acceptance of the last bid and is perfected as of 8:00 a.m. on the date of the sale if the trustee’s deed is recorded within 15 days. The statutory finality provision creates strong BFP protection for the winning bidder. However, as the California Court of Appeal held in OC Interior Services, LLC v. Nationstar Mortgage, LLC, even a buyer who qualifies as a BFP under § 2924h cannot rely on a void judgment canceling a prior lien — if that judgment was itself void, the prior lien revives and burdens the title notwithstanding the BFP’s good faith and the recording. (Secondary analysis, https://moneyanddirt.com/2017/03/even-a-bona-fide-purchaser-cant-rely-on-a-void-judgment/, retrieved 2026-06-10.)
How jurisdictions diverge
| Jurisdiction | BFP protection mechanism | Void sale: BFP cure? | Key authority |
|---|---|---|---|
| North Carolina | G.S. 1-108 (judicial sale); voidable-not-void rule for procedural defects | No (constitutional defects void) | In re Ackah (2018); In re George (2021) |
| South Carolina | § 12-51-160 prima facie deed; 2-yr SOL | No (jurisdictional defects void) | Leysath v. Leysath (1946); § 12-51-160 |
| Ohio | ORC § 5721.39 incontestable title | Partial (notice required; irregularities cured) | ORC § 5721.39 |
| Michigan | MCL 211.78l 2-yr SOL; interests extinguished | No (due process violations may revive; title companies require 20 yrs) | MCL 211.78l; In re Wayne County (2007) |
| Illinois | 735 ILCS 5/2-1401(e) (no jurisdictional defect on face of record) | No (jurisdictional defect on record defeats BFP) | JP Morgan Chase v. Robinson (2020) |
| California | Civil Code § 2924h finality (non-judicial) | No (void prior judgment revives prior lien) | OC Interior Services v. Nationstar |
| Pennsylvania | No statutory BFP cure; strict compliance rule | No — defective notice = void ab initio | In re Sale by Lackawanna Cty., 255 A.3d 619 (Pa. Cmwlth. 2021) |
| Florida | § 695.01(2) recording; § 95.192 4-yr bar on tax deed challenges | Partial (4-yr bar, homestead void exception) | Fla. Stat. §§ 95.192, 695.01 |
needs_verification: Florida homestead deed void ab initio rule (no spousal joinder) and South Carolina Leysath exact holding confirmed from secondary sources; primary opinion text not retrieved. Ohio ORC § 5721.39 incontestability language confirmed from primary source (codes.ohio.gov). Michigan 20-year title insurance practice confirmed from secondary sources (title underwriter practice, not statute).
Special issues in the tax-sale context
IRS federal tax lien — BFP does not extinguish the 120-day redemption right
A good-faith purchaser at a state tax sale does not extinguish a pre-existing federal tax lien unless the United States was properly noticed and given an opportunity to redeem. Under 26 U.S.C. § 7425 and 26 C.F.R. § 301.7425-4, the United States holds a 120-day right of redemption after a tax sale that extinguishes a federal lien; the IRS may redeem by paying the purchase price plus interest and certain costs. If the United States was not noticed before the sale, the federal lien survives the sale regardless of how innocent the buyer was. (Federal Tax Liens and the United States Right of Redemption, Stewart Title analysis, https://www.stewart.com/en/insights/fed-tax-liens-and-us-redemption, retrieved 2026-06-10; IRS IRM § 5.12.5, https://www.irs.gov/irm/part5/irm_05-012-005r, retrieved 2026-06-10.) See federal-tax-lien-redemption.
Price adequacy and the good-faith inquiry
Courts in several states have held that while a grossly inadequate price alone is not sufficient to defeat BFP status, it is strong circumstantial evidence of bad faith and triggers enhanced scrutiny of the buyer’s conduct. In re George (NC 2021) is the leading recent case on this point: the Supreme Court reversed a lower-court finding that KPC Holdings was not a good-faith purchaser, but did so based on the totality of the circumstances rather than ruling that price can never matter. Compare Georges v. KPC Holdings (the Court of Appeals intermediate decision), which had allowed the prior owner to recover the home. The lesson for purchasers at auction: a very low price increases the risk that a court will demand strong evidence of due diligence.
Constructive notice from recorded instruments — inquiry notice
A buyer has constructive notice of every instrument that is properly recorded in the chain of title. In race-notice and notice jurisdictions, this means the buyer must actually examine the record. In pure-race jurisdictions (NC, DE, LA), recording priority is all that matters for recording-act purposes — but a buyer who actually knows of a defect can still lose BFP status in a judicial-sale protection analysis even in a pure-race state, because the judicial-sale statute asks about good faith at the time of purchase, a separate inquiry from recording priority.
In addition, possession of property by a third party is generally inquiry notice — a buyer who does not investigate the possessor’s claim acts at risk. This is a common trap in tax-sale purchases where the original owner or a tenant remains in occupancy.
HOA and municipal assessment lien sales
The Ackah and George cases both arose out of HOA lien foreclosures (Ch. 47F/47C in North Carolina), not county tax sales. The G.S. 1-108 BFP protection applies to both — the statute covers any “judgment” entered by a court or clerk, including HOA power-of-sale proceedings ordered by the clerk of superior court. The principle is the same: a good-faith purchaser at the court-ordered sale keeps title even if the underlying order is later vacated. See hoa-super-priority.
Framing: two audiences
▸ For Investors / Operators
Good-faith-purchaser status is the central title-safety question at any auction purchase. Know your state’s rule before bidding: Is the BFP doctrine codified (NC G.S. 1-108, SC § 12-51-160, OH § 5721.39) or purely common-law? What constitutes good faith — passive reliance on the sale notice, or affirmative due diligence? Is the sale type (judicial, clerk-ordered, non-judicial trustee, county treasurer) the kind that triggers the statutory protection? Grossly inadequate price increases scrutiny; affirmative pre-bid title review (service records, mailing affidavits) provides the best defense. In all states, a valid federal tax lien noticed by the IRS before the sale survives and creates a 120-day redemption risk that BFP status does not cure.
▸ For Former Owners / Lienholders
Whether BFP protection defeats your challenge depends entirely on the type of defect. Jurisdictional and constitutional failures (no notice at all, sale of exempt property, sale without statutory authority) are typically void — BFP status does not protect the buyer and you may still challenge the deed. Procedural and technical failures are typically voidable — once a BFP takes title and the limitations period runs, your challenge to the property itself is extinguished. Your remedy in that posture is monetary (restitution from the foreclosing party) or a surplus-funds claim if proceeds were distributed. Document the notice failure, identify whether it is jurisdictional or not under your state’s law, and move within any applicable limitations window.
Leading cases
- in-re-foreclosure-of-ackah — In re Foreclosure of Ackah, 804 S.E.2d 794 (N.C. Ct. App. 2017), aff’d No. 334A17 (N.C. 2018): G.S. 1-108 shields good-faith purchaser even when underlying HOA foreclosure order is set aside for defective notice; ousted owner’s remedy is monetary.
- In re George, No. 77A19 (N.C. Sup. Ct. 2021): Totality-of-circumstances test for good faith under G.S. 1-108; grossly inadequate price is a factor but not dispositive; buyer’s affirmative diligence is weighed. (needs_verification: primary text not retrieved.)
- Leysath v. Leysath, 209 S.C. 342, 40 S.E.2d 233 (S.C. 1946): Tax deed as prima facie evidence of good title; burden on party attacking deed; 2-yr SOL bars non-jurisdictional challenges.
- JP Morgan Chase Bank, N.A. v. Robinson, Ill. App. Ct. 2nd Dist. 2020: 735 ILCS 5/2-1401(e) protects BFP only if jurisdictional defect is not apparent on face of record.
- OC Interior Services, LLC v. Nationstar Mortgage, LLC, Cal. Ct. App.: BFP cannot rely on void judgment — title encumbered by prior lien that was canceled through void proceedings.
- jones-v-flowers — Jones v. Flowers, 547 U.S. 220 (2006): Constitutional notice floor; consequences for void/voidable left to state law.
- tyler-v-hennepin-county — Tyler v. Hennepin County, 598 U.S. 631 (2023): Fifth Amendment takings limit on tax forfeiture; constitutional limits override state statute.
Practical playbook
For a bidder at a tax or foreclosure auction
- Identify the sale type. Is this a county treasurer tax-deed sale, a clerk-ordered HOA lien sale, a judicial tax foreclosure, or a non-judicial trustee’s sale? Each type has different statutory BFP protection.
- Research the notice file before bidding. For judicial and clerk-ordered sales: obtain the certificate of service, mailing affidavits, return-receipt records, and the posting record. In states that require strict compliance (PA, SC for jurisdictional defects), any gap is a potential void defect that BFP status cannot cure.
- Check for IRS/federal lien. Run a federal tax lien search (IRS, PACER). If the United States holds a lien and was not properly noticed, a 120-day redemption right survives your purchase regardless of good faith.
- Check possession. Unannounced occupants are inquiry notice. Visit the property or require a vacant-possession certification.
- Assess price vs. due diligence. A very low bid — especially below 10% of market — increases the risk a court will demand evidence of affirmative due diligence. Document your pre-bid title review.
- Know your limitations window. In curative-period states (SC 2 yrs, FL 4 yrs, MI/OH 2 yrs from judgment), the window is finite. In strict-void states (PA), no window cures a fundamental notice failure.
- Title insurance. Many underwriters will not insure tax deeds until a seasoning period passes (FL 4 yrs, SC 2 yrs, MI commonly 20 yrs or a quiet title decree). Factor this into the investment horizon. See quiet-title-after-tax-sale and title-insurance-and-deed-seasoning.
For a former owner or lienholder
- Classify the defect. Void (jurisdictional/constitutional — no cure, no time bar in most states) or voidable (procedural — BFP and limitations window apply)?
- Check for BFP transfer. If the tax-deed grantee has already sold to a third-party BFP, a voidable challenge is extinguished even if the SOL is still open.
- Move within the window. Even in states that do not technically bar void challenges, delay creates practical barriers (laches, changed conditions). Act promptly.
- Monetary remedies survive. Even when the property cannot be recovered from a BFP, you may have a restitution claim against the foreclosing entity or a surplus-funds claim if excess proceeds were distributed.
Cross-links
void-vs-voidable, due-process-notice, right-of-redemption, surplus-funds, quiet-title-after-tax-sale, title-insurance-and-deed-seasoning, federal-tax-lien-redemption, hoa-super-priority, jones-v-flowers, tyler-v-hennepin-county, mullane-v-central-hanover, in-re-foreclosure-of-ackah, north-carolina, south-carolina, third-party-recovery-rules
Sources
| # | Type | URL | Retrieved | Notes |
|---|---|---|---|---|
| 1 | Statute (NC) | https://www.ncleg.net/EnactedLegislation/Statutes/HTML/BySection/Chapter_1/GS_1-108.html | 2026-06-10 | G.S. 1-108 — good faith purchaser at judicial sale |
| 2 | Case (NC) | https://law.justia.com/cases/north-carolina/supreme-court/2021/77a19.html | 2026-06-10 | In re George (NC Sup. Ct. 2021) — totality-of-circumstances BFP test (needs_verification: 403 at primary; citation confirmed from secondary sources) |
| 3 | Secondary (NC) | https://ncbankruptcyexpert.com/2021/05/20/n-c-s-ct-in-re-george-insufficient-service-for-non-judicial-foreclosure | 2026-06-10 | Analysis of In re George — adequacy of price, affirmative diligence |
| 4 | Secondary (NC) | https://natlawreview.com/article/void-valid-good-faith-purchaser-value-keeps-title-despite-procedural-defects | 2026-06-10 | Georges v. KPC Holdings (NC Ct. App. 2019); In re Ackah summary |
| 5 | Statute (SC) | https://www.scstatehouse.gov/code/t12c051.php | 2026-06-10 | SC Code § 12-51-160 (tax deed as prima facie evidence); § 12-51-90 (redemption) |
| 6 | Secondary (SC) | https://www.charlestoncounty.gov/departments/master-in-equity/law-tax-sales.php | 2026-06-10 | SC void/voidable framework; Leysath; 2-yr SOL; jurisdictional exception |
| 7 | Case (SC) | Leysath v. Leysath, 209 S.C. 342, 40 S.E.2d 233 (1946) | — | Confirmed from secondary sources; primary text not directly retrieved |
| 8 | Statute (OH) | https://codes.ohio.gov/ohio-revised-code/section-5721.39 | 2026-06-10 | ORC § 5721.39 — incontestable title after tax foreclosure |
| 9 | Statute (MI) | https://www.legislature.mi.gov/Laws/MCL?objectName=mcl-211-78l | 2026-06-10 | MCL 211.78l — 2-yr SOL; interests extinguished at foreclosure |
| 10 | Statute (IL) | https://www.ilga.gov/legislation/ilcs/ilcs4.asp?DocName=073500050HArt.+II+Pt.+14&ActID=2017&ChapterID=56&SeqStart=16500000&SeqEnd=17000000 | 2026-06-10 | 735 ILCS 5/2-1401(e) — BFP at foreclosure |
| 11 | Secondary (IL) | https://consumerfsblog.com/2020/05/illinois-app-court-2nd-dist-holds-bona-fide-foreclosure-sale-not-voided-by-latent-defect-in-service-of-process/ | 2026-06-10 | JP Morgan Chase v. Robinson — IL 2-1401(e) BFP protection |
| 12 | Secondary (CA void) | https://moneyanddirt.com/2017/03/even-a-bona-fide-purchaser-cant-rely-on-a-void-judgment/ | 2026-06-10 | OC Interior Services v. Nationstar — BFP cannot rely on void judgment (CA) |
| 13 | General (BFP) | https://www.law.cornell.edu/wex/bona_fide_purchaser | 2026-06-10 | Cornell LII definition and elements |
| 14 | Secondary (BFP) | https://law.jrank.org/pages/9188/Personal-Property-Bona-Fide-Purchasers.html | 2026-06-02 | BFP void/voidable common-law rule |
| 15 | Federal (IRS lien) | https://www.irs.gov/irm/part5/irm_05-012-005r | 2026-06-10 | IRS IRM § 5.12.5 — 120-day redemption right |
| 16 | Secondary (IRS lien) | https://www.stewart.com/en/insights/fed-tax-liens-and-us-redemption | 2026-06-10 | Federal tax lien survives sale if US not noticed; BFP does not extinguish |
| 17 | Secondary (recording) | https://kinglawoffices.com/civil-disputes/the-implications-of-nc-pure-race-statute-in-recording/ | 2026-06-10 | NC pure-race statute; notice irrelevant for recording priority |
| 18 | Case (USSC) | https://www.law.cornell.edu/supremecourt/text/339/306 | 2026-06-02 | Mullane, 339 U.S. 306 (1950) |
| 19 | Case (USSC) | https://www.law.cornell.edu/supremecourt/text/462/791 | 2026-06-02 | Mennonite, 462 U.S. 791 (1983) |
needs_verification summary: (a) In re George, No. 77A19 (N.C. Sup. Ct. 2021): docket number and date confirmed from multiple secondary sources; primary opinion text not retrieved from Justia (403). Holdings stated above rely on secondary summaries; verify against primary before litigation use. (b) Leysath v. Leysath, 209 S.C. 342 (1946): citation confirmed across multiple secondary sources; primary text not retrieved. (c) Michigan title-company 20-year seasoning practice: widely reported in secondary sources but not codified in a statute or court rule; verify with a Michigan title underwriter. (d) Florida § 95.192 homestead-void exception: mentioned in secondary sources; primary statutory text of homestead void rule (Art. X, Fla. Const.) not retrieved.
Legal information, not legal advice. This page is a research reference for educational and informational purposes only. It does not constitute legal advice and does not create an attorney-client relationship. The good-faith purchaser doctrine varies significantly by jurisdiction and changes with legislation and case law. Verify all statutes, rules, and case holdings with a licensed attorney in the relevant jurisdiction before taking any action. Laws cited here were accurate as of last_verified: 2026-06-10.