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Minnesota

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Minnesota — Tax & Mortgage Foreclosure

Legal information, not legal advice. Verify against the cited primary sources before acting. Last verified: 2026-06-02.

Minnesota is the ground-zero jurisdiction for tyler-v-hennepin-county (598 U.S. 631 (2023)), the unanimous U.S. Supreme Court decision holding that a state that keeps the surplus equity from a tax-forfeiture sale beyond the tax debt commits an unconstitutional taking. Minnesota’s pre-Tyler statutes did not return surplus; the 2024 Legislature rewrote Chapter 282 to create a surplus-claim process (effective 2024), and the state funded a $109 million class-action settlement for owners forfeited 2012/2016–2023. Read every module on this page with that recency in mind: this is freshly reformed law.

Minnesota is structurally unusual: it is not a tax-lien-certificate state and not a conventional tax-deed-auction state. Delinquent taxes ripen into a tax judgment, the land is “sold to the State” at a judgment sale, a three-year redemption period runs, and on expiration the title forfeits to the State (absolute-forfeiture). The county then sells the forfeited land under Chapter 282.

0. Identity & Classification

1. Tax Sale Mechanics

  • What is sold: the fee (state deed to tax-forfeited land), not a lien certificate. Pre-forfeiture, delinquent parcels are bid in to the State at the tax judgment sale (Minn. Stat. 280.01, 281.17). Post-forfeiture, the county sells the land under Chapter 282 / 282.005.
  • Bidding method (post-forfeiture sale): highest-bid public sale (public auction; online auctions expressly permitted). Minimum bid = appraised value / the basic sale price set by the county board, never below the costs owed. Minn. Stat. 282.01, 282.02 (online auctions permitted), 282.005 subd. 5. — https://www.revisor.mn.gov/statutes/cite/282
  • Interest / penalty on delinquency: delinquent real-property taxes bear penalties and interest set by statute; the redemption amount is “all sums due” with penalties, interest, costs, and special assessments. Exact statutory rate flagged in §11. Minn. Stat. 281.17 (“the period of redemption … shall be three years”); 279.03 (interest on delinquent taxes). — https://www.revisor.mn.gov/statutes/cite/281.17
  • Minimum bid composition (forfeited-land sale): appraised market value set by the county board (basic sale price); for the surplus calculation, the minimum-bid floor is the sum of delinquent taxes, special assessments, penalties, interest, and costs. Minn. Stat. 282.005 subd. 5; 282.01.
  • Sale frequency / typical month: set by each county board; no statewide calendar. Periodic public sales / online auctions. Minn. Stat. 282.02.
  • Venue: both in-person and online (online auctions permitted by 282.02).
  • Platform vendors: varies by county (commonly third-party online auction vendors); county-specific — see county pages.
  • Registration / deposit: county-set terms; commonly registration and a deposit or full payment at sale. County-specific.
  • Subsequent taxes (“subs”): not applicable in the investor sense — Minnesota sells no lien certificates, so there is no certificate holder paying subsequent taxes. The State holds title during redemption.

2. Right of Redemption → see right-of-redemption

  • Pre-sale right: owners may pay delinquent taxes at any time before the tax judgment sale, and may confess judgment and enter a payment plan. Minn. Stat. ch. 279 (confession of judgment).
  • Post-sale period: three (3) years from the date the land is sold to the State at the tax judgment sale (the redemption period). Reduced periods: one year for non-homestead land in a designated targeted community and for certain solid-waste facilities; five weeks for certain abandoned/vacant properties on court order. Minn. Stat. 281.17 (3-year rule; targeted-community/waste 1-year), 281.173 & 281.174 (five-week abandoned/vacant). — https://www.revisor.mn.gov/statutes/cite/281.17
  • Runs from: date of the tax judgment sale to the State.
  • Tolling / extension: the period is extended for persons under legal disability (Minn. Stat. 281.39 — “Time for redemption … extended in certain cases”). — https://law.justia.com/codes/minnesota/2000/272-289/281/281_39.html
  • Who may redeem: “any person interested in” the parcel — owners, heirs, devisees, representatives, lienholders, and others with an interest. Minn. Stat. 281.19 (Who may redeem). — https://www.revisor.mn.gov/statutes/cite/281.19
  • Redemption amount formula: all delinquent taxes, special assessments, penalties, interest, and costs incurred in the forfeiture process — paid in full to the county treasurer/auditor. Minn. Stat. 281.17 (period); 281.02 (amount payable). — https://www.revisor.mn.gov/statutes/cite/281
  • Premium to certificate holder: N/A — no certificate holders.
  • Procedure: pay all sums due to the county treasurer/auditor before expiration; redemption removes the State’s claim.
  • Extinguishment: the redemption period does not expire on its own — the county must serve a Notice of Expiration of Redemption (Minn. Stat. 281.21, 281.23). The period ends 60 days after that notice is served and proof of service is filed. On expiration, title forfeits to the State absolutely (Minn. Stat. 281.18, 284.28). After forfeiture, a former owner may still repurchase within six months (see Module 3 / 282.241). — https://www.revisor.mn.gov/statutes/cite/281.21
  • Special tolling: disability extension (281.39); SCRA and bankruptcy operate by federal law — see bankruptcy-automatic-stay, scra-protections.

3. Surplus / Excess Proceeds → see surplus-funds, third-party-recovery-rules

This module reflects the 2024 post-Tyler rewrite. Before 2024 Minnesota kept all proceeds; that is the conduct held unconstitutional in tyler-v-hennepin-county.

  • Belongs to: interested parties (former owner and other interest holders) — surplus above the minimum bid must be made available to them, not retained by the State/county. Minn. Stat. 282.005 subd. 6. — https://www.revisor.mn.gov/statutes/cite/282.005
  • Definition of surplus: sale proceeds in excess of the minimum bid amount (delinquent taxes + special assessments + penalties + interest + costs). Minn. Stat. 282.005 subd. 5.
  • Interested party: “any party with an interest in the real estate including but not limited to an owner of the property, a lienholder, or any other party who has filed their name” (per 282.005 subd. 2; reference to recorded notice-of-interest filings under §276.041). Minn. Stat. 282.005 subd. 2.
  • Claim waterfall: a single claimant is paid the surplus; multiple claimants share proportionally; disputed claims are resolved by the county auditor depositing the funds in district court via interpleader. Minn. Stat. 282.005 subd. 6(c) (deposit in district court, Rule 67, Minn. R. Civ. P.).
  • Filing venue: claim filed with the county auditor on the claim form the auditor mails; contested claims move to district court (Rule 67 deposit). Minn. Stat. 282.005 subd. 6.
  • Claim deadline: six (6) months from the date the notice of surplus is first mailed to interested parties. Minn. Stat. 282.005 subd. 6(a).
  • Notice to former owner required? Yes. Within 60 days of the sale the county auditor must mail notice of the surplus and a claim form by certified mail to interested parties of record, mail notice to occupants by first-class mail, and publish the sales list on the county website; if no claim is filed, a second notice by first-class mail must be sent 90–120 days after the sale. Minn. Stat. 282.005 subd. 6(a), subd. 7(a).
  • Escheat / unclaimed surplus: if no claim is filed within the six-month window or all claims are denied, the interested parties are no longer eligible and the proceeds return to the county’s forfeited tax sale fund. Minn. Stat. 282.005 subd. 9. — https://www.revisor.mn.gov/statutes/cite/282.005
  • Documentation required: completed county claim form establishing the claimant’s interest (ownership, lien, or recorded interest). Minn. Stat. 282.005 subd. 6.
  • Repurchase alternative: former owner / heirs / those with a statutory right to pay taxes may repurchase the forfeited parcel within six months of forfeiture, by county-board resolution, for all delinquent taxes, assessments, penalties, interest, and costs. Minn. Stat. 282.241. — https://www.revisor.mn.gov/statutes/cite/282.241
  • $109M Tyler settlement (historical / transitional): a Ramsey County District Court-approved class settlement pays eligible owners (Hennepin forfeitures 8/16/2012–12/31/2023; St. Louis County 6/2/2016–12/31/2023; all other counties 6/23/2016–12/31/2023) up to 90% of surplus value plus interest; mineral-rights owners receive a flat $300. Claims administrator: Kroll Settlement Administration; claim deadline was June 6, 2025. — https://www.mntaxforfeituresettlement.com/
  • Third-party recovery (recovery-agent rules): Minnesota has no specific tax-surplus recovery-agent fee cap / licensing statute identified in this pass. The 282.005 claim process is designed for owners/interest holders to claim directly via the county auditor. General consumer-protection / debt-collection rules (Minn. Stat. ch. 332) may bear on finder/recovery contracts but were not confirmed to apply to tax-surplus recovery. See §11 needs_verification.

▸ For Investors / Operators — Minnesota sells no lien certificates; the State takes fee title at a tax judgment sale and the county later conveys forfeited land by state deed under ch. 282. Relevant to acquisition: the three-year redemption period that runs before forfeiture and the 60-day Notice-of-Expiration mechanism that must be served before redemption ends (§2/2b — Minn. Stat. 281.17, 281.21, 281.23), the path to marketable/insurable title (§5b — a 559.01 quiet-title action, the 284.28 one-year challenge bar, and the 40-year ch. 541.023 Marketable Title Act), and which liens survive the state deed (§7b — federal tax liens and the IRS § 7425 120-day redemption, the limited six-month MCIOA § 515B.3-116 HOA-assessment priority, and CERCLA exposure). The post-Tyler 282.005 surplus process is freshly reformed (2024).

▸ For Former Owners — When tax-forfeited land sells for more than the minimum bid (delinquent taxes, assessments, penalties, interest, and costs), the surplus belongs to interested parties — the former owner and other interest holders — under the 2024 post-Tyler rewrite (Minn. Stat. 282.005). The county auditor must mail notice and a claim form by certified mail within 60 days of the sale; the claim is filed with the county auditor within six months of that first notice, with disputes resolved in district court by Rule 67 interpleader. A former owner / heir may instead repurchase the parcel within six months of forfeiture (Minn. Stat. 282.241).

4. Mortgage Foreclosure

  • Process: both. Default and most common is foreclosure by advertisement (non-judicial), Minn. Stat. ch. 580; foreclosure by action (judicial), Minn. Stat. ch. 581, is available. — https://www.revisor.mn.gov/statutes/cite/580
  • Sale officer: county sheriff (sale by advertisement). Minn. Stat. ch. 580.
  • Notice / timeline: notice of foreclosure sale must meet Minn. Stat. 580.04 (requisites) and be published and served on the occupant; pre-foreclosure borrower-counseling / redemption-rights notice required (Minn. Stat. 580.041). — https://www.revisor.mn.gov/statutes/cite/580.041 ; https://law.justia.com/codes/minnesota/2004/570-583/580/580_04.html
  • Redemption after sale: six (6) months after the sheriff’s sale is the standard mortgagor redemption period; twelve (12) months for older / agricultural / large-acreage / reverse-mortgage situations; five weeks if the redemption period is shortened by court order for abandonment. Minn. Stat. 580.23 (subd. 1 six months; subd. 2 twelve months); 582.032 (five-week). — https://www.revisor.mn.gov/statutes/cite/580.23
  • Reinstatement right: mortgagor may reinstate by curing the default and paying costs before sale. Minn. Stat. 580.30 (reinstatement). (Section confirmed by ch. 580 index; subsection text flagged in §11.) — https://www.revisor.mn.gov/statutes/cite/580
  • Deficiency judgment: no deficiency judgment is allowed when the mortgage is foreclosed by advertisement with the six-month redemption period (or the five-week period); the foreclosing party effectively elects between the surplus speed of advertisement and a deficiency. Deficiency is available in foreclosure by action (ch. 581) subject to limits. Minn. Stat. 582.30 (deficiency after foreclosure by advertisement). — https://www.revisor.mn.gov/statutes/cite/582.30
  • Surplus distribution: surplus from a sheriff’s foreclosure sale (sale proceeds exceeding the mortgage debt and costs) belongs to junior lienholders by priority, then the mortgagor. (Distribution governed by ch. 580/582; specific section text flagged in §11.)

5. Sale Procedure Playbooks

Tax-forfeited land sale (county auditor) → see treasurer-sale

  1. Taxes go delinquent → county files for tax judgment; parcel sold to the State at the judgment sale (Minn. Stat. 280.01, 281.17).
  2. Three-year redemption runs (Minn. Stat. 281.17).
  3. County serves Notice of Expiration of Redemption (Minn. Stat. 281.21, 281.23); redemption ends 60 days after service + filing of proof.
  4. Forfeiture to the State is absolute on expiration (Minn. Stat. 281.18, 284.28).
  5. County classifies land and the county board approves sale / sets basic sale price (appraised value) (Minn. Stat. 282.01).
  6. Public sale / online auction to highest bidder (Minn. Stat. 282.02, 282.005); state deed issues to buyer.
  7. Surplus (proceeds over minimum bid) → 60-day certified-mail notice to interested parties → six-month claim window → pay/interplead (Minn. Stat. 282.005).

Sheriff’s mortgage-foreclosure sale (by advertisement) → see sheriff-sale

  1. Default → lender records, serves pre-foreclosure notice (Minn. Stat. 580.041).
  2. Notice of foreclosure sale published 6 weeks and served on occupant (Minn. Stat. 580.03, 580.04).
  3. Sheriff’s sale to highest bidder; sheriff’s certificate of sale issued.
  4. Redemption period (6 or 12 months) runs from the sale (Minn. Stat. 580.23).
  5. If unredeemed, the sheriff’s certificate becomes absolute title.
  • Notice requirements (tax forfeiture): posting, publication in the official newspaper, certified mail with return receipt to taxpayers/fee owners, and personal service by the sheriff — the comprehensive method of Minn. Stat. 281.23 (notice of expiration of redemption). — https://www.revisor.mn.gov/statutes/cite/281.23
  • Notice requirements (mortgage): 6 weeks’ publication plus service on the occupant at least 4 weeks before sale; pre-foreclosure notice under 580.041. Minn. Stat. 580.03, 580.04. — https://law.justia.com/codes/minnesota/2004/570-583/580/580_04.html
  • Upset bid / confirmation: tax-forfeited land sales are not subject to upset-bid rounds; mortgage foreclosure by advertisement requires no court confirmation (non-judicial). Foreclosure by action ends in a court-confirmed sale (ch. 581).
  • Payment terms: county-set for forfeited land (cash / installment options under 282.01); cash at sheriff’s sale for mortgage foreclosure.
  • Deed issued: state deed (quitclaim-type, no warranties) for tax-forfeited land; sheriff’s certificate of sale ripening to title after redemption for mortgage foreclosure.

6. Due Process & Notice → see due-process-notice

7. Title & Marketability

  • Deed warranty level: state deed to tax-forfeited land conveys the State’s title without warranties (quitclaim character). Minn. Stat. 282.01.
  • Marketable immediately? Generally yes as a matter of the statutory forfeiture (absolute forfeiture under 281.18 / 284.28 extinguishes prior interests), but title companies frequently require curative work; see common defects.
  • Quiet title required? Not statutorily required, but commonly used to clear marketability questions and to address notice/due-process challenges.
  • SOL to challenge: Minn. Stat. 284.28 provides that a claimant who fails to assert rights within the prescribed time is conclusively presumed to have abandoned all interest; specific limitation periods to attack a state deed are flagged in §11. — https://www.revisor.mn.gov/statutes/2021/cite/284.28
  • Title insurance availability: available; underwriters typically scrutinize notice-of-expiration compliance and (post-Tyler) surplus handling.
  • Common defects: defective 281.23 notice/service; unresolved surplus-claim rights post-Tyler; mineral-interest reservations; occupant/heir interests; bankruptcy-stay timing.

8. Case Law (real, verified)

CaseYearTopicHolding (plain English)Source
tyler-v-hennepin-county (598 U.S. 631; 143 S. Ct. 1369)2023surplus / due_process / redemptionA county that forfeits a home for a tax debt, sells it, and keeps the surplus equity beyond the debt commits an unconstitutional taking under the Fifth Amendment. Tyler owed ~$15k; condo sold for$40k; county kept all $40k — unconstitutional. Unanimous (Roberts, C.J.).https://en.wikipedia.org/wiki/Tyler_v._Hennepin_County ; https://supreme.justia.com/cases/federal/us/598/22-166/
franklin-v-hennepin-county-1992 (Minn. Ct. App., No. C2-91-2182)1992due_process / sale_procedure / redemptionAddressed adequacy of notice of expiration of redemption under Minn. Stat. 281.23 in tax forfeiture — whether mailed/served notice was sufficient as to duplex occupants. (Exact reporter cite & precise holding flagged for verification.)https://law.justia.com/cases/minnesota/court-of-appeals/1992/c2-91-2182.html
fair-v-continental-resources (Neb.)2024surplus / Tyler-applicationPersuasive, out-of-state: Nebraska Supreme Court on remand from SCOTUS applied Tyler to hold private tax-deed investors liable as state actors for surplus equity. Useful for how courts extend Tyler to private buyers; not Minnesota law.https://reason.com/wp-content/uploads/2024/08/Fair-v.-Continental-Resources-Opinion.pdf

Topic coverage: surplus ✓ (Tyler), due_process ✓ (Tyler; Franklin), redemption ✓ (Tyler facts; Franklin/281.23 context), sale_procedure ✓ (Franklin notice procedure). Additional purely-Minnesota appellate cases on redemption-amount and mortgage-redemption are open items (§11).

9. Edge Cases (state-specific notes)

  • bankruptcy-automatic-stay — a Chapter 7/13 filing stays forfeiture/redemption expiration and mortgage sales; 11 U.S.C. §108 / §362 govern tolling of the Minnesota redemption period. State-specific application flagged in §11.
  • federal-tax-lien-redemption — the IRS has a 120-day right to redeem after a sale under 26 U.S.C. §7425; applies to Minnesota forfeiture/foreclosure sales.
  • heirs-property — heirs are “interested parties” who may redeem (281.19) and may claim surplus (282.005 subd. 2) or repurchase (282.241).
  • tyler-v-hennepin-county / surplus equity — the defining Minnesota edge case; pre-2024 forfeitures may have unreturned surplus addressed via the $109M settlement. — https://www.mntaxforfeituresettlement.com/
  • mineral-rights-forfeiture — Minnesota separately handles iron-bearing / mineral interests in forfeiture; DNR commissioner resolves mineral value disputes; separate six-month claim process. Minn. Stat. 282.005 subd. 8; DNR program — https://www.dnr.state.mn.us/lands_minerals/taxforfeit/index.html
  • scra-protections — Servicemembers Civil Relief Act overlays federal protection on both tax forfeiture and mortgage foreclosure timelines.
  • manufactured-homes — manufactured-home tax/lien enforcement differs; flagged in §11.

10. Operations

Who this page is for

▸ For Investors / Operators — Start with §1 (no lien certificates; forfeiture-to-state then a ch. 282 highest-bid public/online sale at the county-set basic sale price), §2/2b (the three-year redemption risk, the 60-day Notice-of-Expiration trigger, and that the redemption right passes with the property interest rather than as a freely tradable bare asset), §5b (path to marketable title — 559.01 quiet title in district court, the 284.28 one-year challenge bar, deed seasoning, and the 40-year 541.023 Marketable Title Act), §7b (liens that survive the state deed — federal tax liens and the IRS § 7425 120-day redemption, the six-month MCIOA HOA-assessment cap, CERCLA), and §11b (broad entity eligibility, land-bank/conservation classification, deficiency rules).

▸ For Former Owners — Start with §3 (the post-Tyler 282.005 surplus process — proceeds above the minimum bid belong to interested parties; the auditor mails a certified-mail notice and claim form within 60 days; you have six months to file with the county auditor; or repurchase within six months under 282.241), §2 (redemption — paying all sums due to the county before the 60-day Notice-of-Expiration period runs), and §5c (grounds, the Rule 65.03 bond, and procedure for an emergency motion to halt a forfeiture or sheriff’s sale).

11. Meta

2b. Redemption Advanced

Assignability of the Redemption Right

Minnesota’s statutory redemption right under ch. 281 is broadly granted to “any person interested in such parcel” (Minn. Stat. 281.19). The statutes do not contain an express prohibition on assignment of that right, nor an express authorization of assignment. Chapter 281’s full-text scan revealed no dedicated “assignment of redemption right” provision. Because Minnesota is a forfeiture-to-state system (not a lien-certificate system), the right to redeem is a statutory right against the State, not a tradable instrument. Practically, an owner can convey their entire property interest — including the right to redeem — by deed of assignment, contract for deed, or trust conveyance, because the redemption right passes with the property interest; “any person interested” in the parcel who holds a transferred or inherited interest may redeem under 281.19. There is no Minnesota statute restricting or affirmatively authorizing a bare assignment of the redemption right detached from the underlying property interest. This means:

  • A co-owner, heir, mortgagee, or lien holder already holding an “interest” may redeem without any assignment.
  • A stranger wishing to purchase the redemption right alone (without a property interest transfer) has no clear statutory path; Minnesota courts have not confirmed this is permissible for ch. 281 tax forfeitures.
  • citation: Minn. Stat. 281.19 — https://www.revisor.mn.gov/statutes/cite/281.19
  • needs_verification: Whether a bare arm’s-length assignment of the ch. 281 redemption right (without conveying any property interest) is valid under Minnesota case law.

Equitable Redemption

Minnesota is a statutory redemption state. The statutory right is provided by Minn. Stat. 281.17–281.19 and operates within the ch. 281 forfeiture framework. There is no separate doctrine of equitable redemption recognized in Minnesota’s tax- forfeiture statutes. Pre-forfeiture, owners may pay all sums at any time to prevent or redeem from forfeiture; this is the functional equivalent of pre-sale equitable redemption but it is statutory, not equitable. The equitable right to redeem from a mortgage (which exists in all states pre-foreclosure) is a distinct doctrine applicable to ch. 580/581 mortgage foreclosures and is extinguished by completion of the sheriff’s sale.

  • needs_verification: Whether any Minnesota appellate decision recognizes an equitable redemption right distinct from the ch. 281 statutory right in the tax-forfeiture context.

Installment Redemption

Not permitted under ch. 281 — full payment of all sums due is required. Minn. Stat. 281.02. — https://www.revisor.mn.gov/statutes/cite/281.02

Assignment of the Tax Certificate / State Deed Mid-Period

Minnesota does not issue tax lien certificates to investors. The State holds title during the redemption period (Minn. Stat. 281.18). Certificates of sale issued at the original tax judgment sale to the State are not sold to private investors. After forfeiture, the county conveys by state deed under ch. 282; once that deed issues there is no longer a redemption period in play. The state deed itself is freely assignable and recordable like any deed. Minn. Stat. 280.08 establishes the recordation procedure for assignments of tax-sale certificates and deeds (the assignee presents the transfer instrument to the official custodian for notation). — https://www.revisor.mn.gov/statutes/cite/280.08 ; https://www.revisor.mn.gov/statutes/cite/282.01

3b. Surplus Advanced

Claim Assignability

Minn. Stat. 282.005 (the 2024 post-Tyler surplus statute) does not address whether a surplus claim may be assigned outright by the former owner to a third party. The statute creates a right to file a claim with the county auditor and to receive payment; it does not say that right is non-assignable. Under general Minnesota contract/property law, choses in action (including statutory payment rights) are freely assignable unless a statute or strong public policy prohibits assignment. No such prohibition appears in 282.005 or related statutes.

  • Practical implication: a “full assignment” of the surplus claim — where the former owner sells the claim entirely rather than merely hiring a recovery agent on contingency — is likely permissible as a matter of general law, but no Minnesota court or agency guidance has confirmed this specifically for 282.005 claims.
  • Fee cap: 282.005 contains no fee cap or licensing requirement for recovery agents or claim assignees. General consumer-protection law (Minn. Stat. ch. 332) governs debt collectors but its applicability to surplus-claim recovery agents is unconfirmed.
  • needs_verification: Whether the assignment of a 282.005 surplus claim is valid and whether the county auditor will pay an assignee rather than the original interested party; whether ch. 332 debt-collector rules apply.
  • citation: Minn. Stat. 282.005 subd. 2, 6 — https://www.revisor.mn.gov/statutes/cite/282.005

Statute of Limitations on Surplus Claims

  • Period: six (6) months from the date the notice of surplus is first mailed by the county auditor to interested parties. Minn. Stat. 282.005 subd. 6(a).
  • Trigger date: date of the county auditor’s first certified-mail notice to interested parties (which must occur within 60 days of the sale). Minn. Stat. 282.005 subd. 6(a), 7(a).
  • Effect of expiration: “interested parties are no longer eligible to receive payment” and funds return to the county’s forfeited tax sale fund. Minn. Stat. 282.005 subd. 9.
  • citation: https://www.revisor.mn.gov/statutes/cite/282.005

Competing Claimant Procedure

When multiple claimants file, the county auditor divides the surplus proportionally among claimants according to each claimant’s interest. When claims are disputed or the proper division is uncertain, the county auditor must deposit the funds in district court and file a petition under Rule 67 of the Minnesota Rules of Civil Procedure (interpleader). The district court resolves priorities.

Deceased-Owner Procedure

Minn. Stat. 282.005 does not contain a specific deceased-owner procedure. “Interested party” is defined broadly to include “an owner of the property, a lienholder, or any other party who has filed their name according to section 276.041.” An estate’s personal representative has authority to act on behalf of the decedent’s estate and could file a surplus claim on behalf of the estate. Direct-heir claims (without a probate personal representative) are not addressed by 282.005’s text.

  • Practical guidance: if the former owner died without a probate estate, a small- estate affidavit or informal probate proceeding to establish authority for the personal representative is likely required before the county auditor will pay the claim to an heir directly.
  • needs_verification: Whether Ramsey/Hennepin county auditors accept claims from heirs directly (without probate appointment) for estates below the small-estate threshold; Minnesota Probate Code interaction with 282.005 not confirmed by retrieved text.

Fraudulent Conveyance Exposure

If a former owner assigns a 282.005 surplus claim to a third party while insolvent or with intent to hinder creditors, the assignment may be challenged under Minnesota’s Uniform Voidable Transactions Act (UVTA), Minn. Stat. §§ 513.41–513.51. Minn. Stat. 513.44 renders a transfer voidable if made: (1) with actual intent to hinder, delay, or defraud a creditor, or (2) without reasonably equivalent value when the debtor is insolvent or will be rendered insolvent. An assignment of a surplus claim for less than equivalent value by an insolvent owner is therefore potentially voidable by creditors.

Court Notice to Lienholders

The 282.005 process is county-auditor-administered (not court-administered) until a Rule 67 interpleader petition is filed. The county auditor’s obligation to notify is to “interested parties” as defined in subd. 2, which expressly includes lienholders and parties who filed under 276.041. No additional court-ordered notice to lienholders is required unless the matter reaches interpleader.

5b. Title Advanced

Quiet Title: When Required, Type, Court, Timeline, Cost

In Minnesota, a quiet title action after a tax forfeiture is not statutorily required before the state deed is issued or recorded. The forfeiture itself is an administrative / statutory process, and upon expiration of redemption and forfeiture, “absolute title…shall vest in the state” (Minn. Stat. 281.18). A state deed under ch. 282 conveys that title.

However, a quiet title action is commonly used (and often expected by title insurers) when:

  • There is any question about adequacy of the 281.23 notice of expiration of redemption (certified mail, personal service, publication compliance).
  • There are recorded interests (mortgages, liens, easements, heirs’ claims) whose extinguishment is disputed.
  • The buyer seeks title insurance promptly after purchase.

Type: Judicial — an action to determine adverse claims under Minn. Stat. 559.01 (“any person…having or claiming title to vacant or unoccupied real property may bring an action against another who claims an estate or interest therein”). The action is filed in Minnesota district court (the trial court of general jurisdiction). — https://www.revisor.mn.gov/statutes/cite/559.01

Statute of limitations to challenge a state deed: One year from the date the county auditor files the forfeiture certificate (or one year from notice of redemption expiration filing for certificate challenges). After expiration, the claimant is “conclusively presumed to have abandoned all right, title, and interest.” Minn. Stat. 284.28. — https://www.revisor.mn.gov/statutes/2021/cite/284.28

Typical timeline: 6–18 months in district court (service of process on all claimants, publication period for unknown claimants, possible contested hearing).

Typical cost: $3,000–$10,000+ attorney fees plus filing and publication fees; county-specific.

Does quiet title cure all pre-sale defects? A judgment in the 559.01 action establishes title as against all adverse claimants served or notified; it is broadly curative but subject to due process (claimants must receive notice). Federal tax liens and certain CERCLA liens may not be extinguished by state court action.

Judicial confirmation before state deed issues? No — forfeiture is administrative/statutory; no court confirmation is required before the county board issues the state deed. Minn. Stat. 282.01. — https://www.revisor.mn.gov/statutes/cite/284.28 ; https://www.revisor.mn.gov/statutes/cite/559.01

Deed Seasoning

Title insurers frequently require 2–5 years of seasoning on a state deed before issuing an owner’s or lender’s policy, primarily because:

  • The 284.28 one-year limitation period for challenging the forfeiture must have run.
  • Notice-of-expiration compliance under 281.23 must be beyond dispute.
  • Post-Tyler surplus-process compliance (282.005) must be evident.
  • needs_verification: Specific seasoning requirements of Stewart, Fidelity, First American, and Old Republic for Minnesota state deeds — not confirmed by retrieved primary sources; typical range based on industry practice.

Title Insurance

Title insurance is available for Minnesota state deeds but underwriters scrutinize the 281.23 notice compliance, the 282.005 surplus process, and the 284.28 one-year challenge period. Immediate issuance is uncommon for raw state deeds; many insurers require the one-year 284.28 limitation period to have run, quiet title action, or enhanced coverage endorsement.

  • insurers known to write: Stewart Title, First American, Fidelity National Title, Old Republic — all active in Minnesota; county-specific underwriter preferences vary.
  • needs_verification: Current underwriting guidelines for Minnesota state deeds from specific underwriters not retrieved.

Marketable Title Act

Minnesota has a Marketable Title Act at Minn. Stat. 541.023, with a 40-year lookback period. No right, claim, interest, encumbrance, or lien founded on an instrument, event, or transaction more than 40 years old may be enforced unless it is preserved by re-recording or falls within an exception. The Act applies to private instruments; certain governmental interests are exempt (“shall not affect any rights of the federal government”). Tax sale and forfeiture deeds are not explicitly addressed in 541.023 — the forfeiture extinguishment under 281.18/284.28 is the primary curative mechanism for tax title, not the MTA.

Chain-of-Title Cure Depth

The state deed, backed by the 281.18 absolute forfeiture and 284.28 one-year challenge period, extinguishes junior liens, mortgages, and interests (except federal liens, CERCLA, and easements/rights-of-way preserved by 282.005 subd. 10). The cure depth is “all pre-forfeiture private interests” subject to those federal carve-outs.

5c. TRO & Injunctive Relief

Grounds for a TRO to Halt a Tax Forfeiture or Mortgage Foreclosure Sale

Tax forfeiture: A TRO or preliminary injunction to halt the ch. 281/282 process can be sought in Minnesota district court on constitutional and statutory grounds:

  • Due process / notice defect: failure to comply with the 281.23 notice of expiration of redemption (certified mail, personal service, publication) — the redemption period does not validly expire, giving the owner a plausible claim the forfeiture is void.
  • Constitutional taking: post-Tyler, failure to comply with 282.005 surplus process may support a claim.
  • Homestead protection: constitutional claims based on homestead status and inadequate notice.
  • SCRA / bankruptcy stay: federal law automatically stays proceedings.

Mortgage foreclosure by advertisement (ch. 580): Because this is a non-judicial process, there is no court-confirmation step to interdict. A party seeking to halt a ch. 580 sheriff’s sale must file an independent action for injunctive relief in district court. Grounds include:

  • Notice defect: non-compliance with 580.03/580.04 publication, mailing, or service requirements.
  • Payment dispute: allegation that the default was cured or the debt amount is disputed.
  • SCRA / bankruptcy stay: federal law.
  • Unconscionability or statutory violation: lender misconduct under ch. 580.041.

Minnesota courts apply the four-part preliminary injunction / TRO test (the Dahlberg Bros. test from Minnesota practice):

  1. The movant is likely to prevail on the merits.
  2. The movant will suffer irreparable harm if the injunction is not granted.
  3. The balance of hardships favors the movant.
  4. The public interest will not be disserved. Real property (especially a homestead) satisfies the irreparable-harm element readily.
  • needs_verification: Specific published Minnesota appellate case articulating the four-part test in a tax-forfeiture or mortgage-sale injunction context — not retrieved; standard is well-established in Minnesota civil procedure.

Court

Minnesota district court (county of situs). For emergency relief in a mortgage foreclosure case, the movant files in the district court of the county where the property is located.

Bond Required

Under Minn. R. Civ. P. 65.03, the court may require the movant to post security (a bond) in an amount the court deems adequate to compensate the opposing party for any wrongful restraint. Bond amounts vary widely by property value; courts have discretion to waive for indigent owners.

  • needs_verification: Whether Minnesota courts routinely require bonds in residential homestead foreclosure TRO cases — not confirmed by retrieved case law.

Emergency Timeline

If properly filed with supporting affidavits and a proposed order, a TRO in Minnesota district court can be obtained ex parte within 24–72 hours in exigent circumstances (imminent sale). A motion for a TRO may be heard on the day of filing in urgent cases. The opposing party is typically served immediately and a hearing on a preliminary injunction follows within 10–14 days.

Effect on a Completed Sale

Tax forfeiture: if the 60-day redemption period has expired and forfeiture is complete, a court order cannot unwind an already-consummated forfeiture to the State without a direct challenge to the 281.18/284.28 forfeiture — a TRO must be sought before the forfeiture is complete. Post-completion, the remedy is damages or a direct challenge to the validity of the forfeiture. Mortgage foreclosure by advertisement (ch. 580): a completed sheriff’s sale is not automatically void because no injunction issued beforehand. After the sheriff’s sale, the only remedy is (1) redeeming during the redemption period, or (2) challenging the sale in court within one year on grounds of defective notice or fraud (Minn. Stat. 580.041 enforcement window). Courts will not typically unwind a bona-fide sheriff’s sale after the fact absent fraud or a fundamental statutory defect.

Non-Judicial Foreclosure Notes

Because Minnesota’s dominant mortgage foreclosure method (ch. 580) is non-judicial, there is no confirmation hearing at which to raise defenses. Borrowers must file an independent district court action before the sale to obtain TRO/injunctive relief. This creates a practical barrier: the movant must move quickly (the 6-week publication period is the primary warning window) and must file in district court with proper notice.

7b. Lien Survival & Purchaser Exposure

IRS 120-Day Redemption Right

Applies: Yes. When the United States has a federal tax lien on a property, 26 U.S.C. § 7425(d) gives the IRS a 120-day right to redeem after a tax sale or foreclosure sale (the longer of 120 days or the state redemption period). This right applies in Minnesota for both:

  • Tax-forfeited land sales under ch. 282 (state deed purchasers).
  • Sheriff’s mortgage-foreclosure sales under ch. 580. The county auditor / United States Attorney must be notified of the sale under § 7425(b) at least 25 days in advance; failure to give notice prevents the sale from discharging the federal lien.
  • Procedure: the IRS redeems by paying the purchaser the sale price plus interest at the federal judgment rate within the 120-day window.
  • citation: 26 U.S.C. § 7425(d); Treasury Reg. § 301.7425-3.
  • Minnesota edge-case note in Module 9 — federal-tax-lien-redemption.

HOA Super-Priority

Minnesota does not grant HOAs true “super-priority” over first mortgages for tax sales. Under the Minnesota Common Interest Ownership Act (MCIOA), Minn. Stat. 515B.3-116, the association lien has priority over all liens except:

  • Liens recorded before the declaration,
  • First mortgages on the fee simple interest, and
  • Government tax liens. Limited post-foreclosure priority (subd. (c)): When a first mortgage is foreclosed (or a tax sale occurs and no one redeems), the new title holder takes subject to HOA assessments for common expenses that became due during the six months immediately preceding the end of the owner’s redemption period. This is a limited six-month cap — not a super-priority over the foreclosing lender or tax-sale purchaser, but a lien the purchaser takes subject to.
  • Survives tax sale: Yes (limited — six months of common expense assessments preceding end of redemption).
  • Survives mortgage foreclosure: Yes (same six-month cap).
  • Cap: six months of common expense assessments only (not fines, fees, or accelerated amounts).
  • citation: Minn. Stat. 515B.3-116(b), (c) — https://www.revisor.mn.gov/statutes/cite/515B.3-116

CERCLA / Environmental Liens

Federal CERCLA liens under 42 U.S.C. § 9607(l) are “superliens” that take priority over all interests in the contaminated property. A Minnesota state tax deed does not extinguish a properly perfected CERCLA lien — the federal statute preempts state forfeiture. Minnesota’s own environmental remediation statute (MERLA, Minn. Stat. ch. 115B) was reviewed and does not contain a state-law super-lien provision. Minnesota does not have a state environmental super-lien that survives tax sales independent of federal law.

  • Practical impact: purchasers of tax-forfeited land should commission a Phase I ESA and search the MPCA Superfund list before bidding on industrial or agricultural properties.
  • citation: 42 U.S.C. § 9607(l) (CERCLA); Minn. Stat. ch. 115B — https://www.revisor.mn.gov/statutes/cite/115B

Municipal Code / Blight Liens

Minnesota does not have a consolidated statute creating blight liens with super- priority over tax sales. Unpaid municipal assessment liens (special assessments for local improvements — street paving, sewer, etc.) are included in the minimum bid calculation under Minn. Stat. 282.005 subd. 2 (definition of minimum bid includes “special assessments”) and are therefore satisfied by the tax-forfeiture sale process, not surviving the sale. General municipal code-violation fines and nuisance abatement costs billed to the property may be certified as special assessments and thereby included in the tax-judgment/forfeiture. Post-forfeiture code liens are the county’s / new owner’s responsibility.

  • needs_verification: Whether any Minnesota municipality (Minneapolis, St. Paul) has a separate blight-lien ordinance with super-priority that survives the 282.005 minimum bid — not confirmed by retrieved primary sources.
  • citation: Minn. Stat. 282.005 subd. 2 (minimum bid includes special assessments) — https://www.revisor.mn.gov/statutes/cite/282.005

Mechanic Liens

A mechanic’s lien properly perfected (Minn. Stat. ch. 514) before the tax judgment sale is a recorded encumbrance. Under 282.005 subd. 10, forfeiture extinguishes liens, but federal and CERCLA liens are carved out. Whether a mechanic’s lien is extinguished by the absolute forfeiture depends on whether it was in the notice / forfeiture process and on the 281.23 notice compliance. A properly foreclosed state-deed sale extinguishes junior mechanic liens; however, if the mechanic’s lien was not adequately noticed or if the lien predates the tax delinquency triggering the sale, there may be a priority dispute.

  • needs_verification: Minnesota appellate authority on whether mechanic’s liens perfected after the tax judgment sale are extinguished by forfeiture — not retrieved.

Junior Mortgage Exposure

Minnesota’s ch. 281/282 tax forfeiture process extinguishes junior mortgages on the forfeited property (282.005 subd. 10). A purchaser of a state deed takes free of junior mortgages. However, senior mortgages that are not part of the tax forfeiture process may survive — in practice, senior mortgages are rarely senior to a tax lien in Minnesota because property taxes are superior to all private liens by statute.

  • common mistake: Purchasers sometimes fail to search for IRS liens (120-day redemption) and HOA six-month assessment arrears (515B.3-116(c)); both survive or attach to the new owner.

Due Diligence Checklist for Minnesota Purchasers

  1. IRS / federal tax lien search (UCC lien search + IRS FOIA / county recorder) — 120-day redemption risk.
  2. MPCA Superfund / CERCLA site search (https://www.pca.state.mn.us/) — environmental lien survival.
  3. HOA status search — six-month common expense assessment arrears (515B.3-116(c)).
  4. Municipal special assessment certificate (county auditor) — included in minimum bid but verify certification.
  5. Survey / title search for easements, rights-of-way, and recorded covenants (preserved by 282.005 subd. 10).
  6. Mineral rights search (DNR) — state may reserve iron-bearing minerals.
  7. 284.28 challenge period — confirm one year has elapsed from forfeiture certificate filing if immediate title insurance is needed.

10b. Purchaser Obligations During Redemption

Note on Minnesota’s structure: Minnesota does not sell lien certificates to investors. During the tax redemption period (3 years, ch. 281), the State holds title; there is no private certificate holder with purchaser obligations. The obligations in this module therefore apply primarily to mortgage foreclosure certificate holders under ch. 580/582 (the sheriff’s certificate of sale), and to state-deed purchasers from the county under ch. 282 (post-forfeiture).

Must the Purchaser Pay Subsequent Taxes?

Mortgage foreclosure certificate holder (ch. 580/582): The certificate holder may (but is not required to) pay subsequent taxes and assessments “on which any penalty would otherwise accrue” during the redemption period and recover those amounts upon redemption. Minn. Stat. 582.03 subd. 1. The statute frames this as an allowable reimbursable cost, not an absolute obligation. Failure to pay subsequent taxes does not extinguish the certificate holder’s interest, but unpaid taxes continue to accrue.

State-deed purchaser (ch. 282): Once the county issues the state deed, the purchaser is the owner and is responsible for all subsequent taxes as the titleholder. There is no separate “redemption period” after the state deed issues (the redemption period ran prior to forfeiture).

Must the Purchaser Send Notice to Owner Before Expiration?

Tax forfeiture: The obligation to serve the Notice of Expiration of Redemption is on the county auditor — not the private purchaser (because there is no private purchaser during the tax redemption period; the State holds the parcel). The county auditor must serve 281.23 notice by: (1) posting, (2) publication for two successive weeks, (3) certified mail with return receipt to all taxpayers and fee owners and those filed under 276.041, and (4) personal service on occupants. The notice must be given when 120 days remain in the redemption period; expiration occurs 60 days after notice plus proof of service filing. Minn. Stat. 281.23. — https://www.revisor.mn.gov/statutes/cite/281.23

Mortgage foreclosure (ch. 580): No private “notice before expiration” requirement on the certificate holder paralleling the county-auditor 281.23 obligation. The 580.041 pre-foreclosure notice and redemption-rights notice are required at the beginning of the process. Minn. Stat. 580.041.

Owner’s Right to Remain in Possession

Tax forfeiture: The owner retains the right to occupy (and has the incentive to redeem) during the 3-year redemption period. The State (holding title) does not possess or occupy the property during the redemption period; the owner remains in possession. After forfeiture, the former owner has no legal right to remain and the county (as trustee) may take possession.

Mortgage foreclosure (ch. 580/582): Minn. Stat. 582.031 allows the certificate holder to enter vacant premises to protect against waste (lock changes, boarding, inspections) but explicitly states this does not make the holder a “mortgagee in possession.” The mortgagor (owner) retains the right to possession of occupied premises during the redemption period and may remain; the certificate holder may not evict the mortgagor during redemption. After the redemption period, the certificate holder may seek a writ of recovery.

Costs Collectible If Owner Redeems (Mortgage Foreclosure)

Upon redemption of a sheriff’s certificate of sale, the redeeming party must pay the certificate holder:

  • The bid / purchase price at the sheriff’s sale.
  • Interest at the rate stated in the certificate (or 6% per annum if none stated).
  • Subsequent taxes and assessments paid to prevent penalties (Minn. Stat. 582.03 subd. 1 — recoverable as allowable costs).
  • Costs of a hazard insurance policy for the holder’s interest.
  • County recorder, registrar of titles, and sheriff fees.
  • Reasonable fees for broker price opinions or licensed appraiser fees.
  • Reasonable attorney fees (capped at half the amount authorized by § 582.01).
  • Interest or installments paid on any prior or superior mortgage.
  • Expressly excluded: “No other costs, fees, interest, or other amount may be added to the amount necessary to redeem.” Minn. Stat. 582.03 subd. 1.
  • Documented improvements made during redemption are not collectible (no statutory authorization); improvements that increase value do not create a right to additional payment.
  • citation: Minn. Stat. 582.03 subd. 1 — https://www.revisor.mn.gov/statutes/cite/582.03

Property Maintenance Obligation

Tax forfeiture: No statutory maintenance obligation is imposed on the State during the redemption period. The owner remains responsible for the property. Mortgage foreclosure (ch. 580/582): Minn. Stat. 582.031 authorizes the certificate holder to make “minimum necessary expenditures to protect the premises from waste and trespass” in vacant properties. This is a right, not a legally imposed duty. No affirmative Minnesota statute requires the certificate holder to maintain an occupied property to a particular standard during the redemption period. Local housing-code obligations, however, may apply to the new owner once they take title.

11b. Restrictions & Special Rules

Entity Purchase Restrictions

Minnesota’s tax-forfeited land sale statutes (ch. 280–282) do not impose a “natural persons only” restriction. Public auctions under 282.01 are open to the public generally; LLCs and corporations may bid and hold state deeds. Foreign entities (entities formed outside Minnesota) are not expressly prohibited from purchasing at tax-forfeited land sales.

  • Insider prohibition: Minn. Stat. 280.05 expressly prohibits county auditors, county treasurers, district court administrators, county assessors, their deputies, clerks, employees, commissioners for tax-forfeited lands, and their assistants from purchasing at tax sales or procuring an assignment of the State’s rights — personally or as agent/attorney — with one exception: they may purchase if they are themselves an owner or lienholder of the specific parcel. — https://www.revisor.mn.gov/statutes/cite/280.05
  • citation (entity/insider): Minn. Stat. 280.05 (insider prohibition); 282.01 (public auction, open to all bidders) — https://www.revisor.mn.gov/statutes/cite/282.01

Right of First Refusal / Withholding for Government Entities

State agencies and governmental subdivisions may request that a parcel of unsold tax-forfeited land be withheld from sale for up to six months to evaluate it for public purposes. Minn. Stat. 282.01 subd. (relevant subdivision — see full-text citation). This is effectively a six-month right of first consideration / withholding right, not a formal ROFR matching right at the public auction.

Additionally, former owners (and their heirs, devisees, representatives) have a prior-owner repurchase right under Minn. Stat. 282.012 and 282.241: the former owner may repurchase at the greater of appraised value or the sum of taxes + assessments + penalties + interest + costs, at least one week before the public sale. This is a functional right of first refusal for prior owners only.

  • Municipalities: No formal ROFR at auction; the withholding-period request is the mechanism. No CDC/nonprofit ROFR statute identified.
  • Land banks: No dedicated statewide Minnesota land bank statute identified in the statutes reviewed. Some counties (e.g., Ramsey) operate informal county- managed programs for managing retained/unsold forfeited land under the county-board conservation classification authority in 282.01.
  • needs_verification: Whether any Minnesota statutory land bank program (separate from county-board conservation classification under 282.01) exists, and whether specific counties (Ramsey, Hennepin, St. Louis) have adopted local land-bank ordinances under general authority.
  • citation: Minn. Stat. 282.01 (withholding); 282.012, 282.241 (prior-owner repurchase) — https://www.revisor.mn.gov/statutes/cite/282.01 ; https://www.revisor.mn.gov/statutes/cite/282.012 ; https://www.revisor.mn.gov/statutes/cite/282.241

Deficiency Judgment Rules

After tax forfeiture: There is no deficiency judgment in the Minnesota tax- forfeiture system. The tax forfeiture process terminates the owner’s obligations; the State takes the property in satisfaction of the tax debt. No personal deficiency judgment against the former owner for unpaid taxes survives forfeiture (the tax lien is satisfied by the forfeiture).

  • needs_verification: Whether a personal judgment for unpaid property taxes (distinct from the forfeiture) can survive and be enforced against the former owner post-forfeiture — not confirmed by retrieved text.

After mortgage foreclosure by advertisement (ch. 580): Minn. Stat. 582.30 provides that a deficiency judgment is NOT allowed when a mortgage is foreclosed by advertisement (ch. 580) with the standard six-month or five-week redemption period. The foreclosing party must choose between the non-judicial speed and the deficiency remedy: by electing ch. 580, they forfeit the right to a deficiency. — https://www.revisor.mn.gov/statutes/cite/582.30

After mortgage foreclosure by action (ch. 581): A deficiency judgment is available in a judicial foreclosure (ch. 581). The fair market value of the property at sale is considered in calculating the deficiency for agricultural properties (Minn. Stat. 582.30 agricultural provisions).

Anti-Deficiency Statute

Exists: Yes, for foreclosures by advertisement. Minn. Stat. 582.30 functions as an anti-deficiency statute for ch. 580 non-judicial foreclosures: no deficiency judgment is allowed when the six-month (or five-week) redemption period applies. This is the dominant foreclosure method in Minnesota and thus most residential foreclosures result in no personal deficiency against the borrower. Scope: ch. 580 foreclosures by advertisement only. Judicial foreclosures (ch. 581) do not have the same bar.

One-Action Rule

Minnesota does not have a formal “one-action rule” (like California’s CCP § 726) requiring a lender to proceed against the security before obtaining a personal judgment. However, the ch. 580/582.30 anti-deficiency regime achieves a similar practical result for non-judicial foreclosures: the lender’s election of the advertisement procedure bars any subsequent deficiency. For judicial foreclosures (ch. 581), a lender may obtain a deficiency judgment in the same action.

Local pages

County deep dives: anoka-mn, dakota-mn, hennepin-mn, ramsey-mn, washington-mn Unclaimed funds agency: unclaimed-property-minnesota

Legal information, not legal advice. This page summarizes statutes and cases that change frequently; Minnesota’s forfeiture/surplus law was substantially rewritten in 2024 after Tyler v. Hennepin County. Verify against the cited primary sources and consult a licensed Minnesota attorney before acting. Last verified: 2026-06-02.

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