Tyler v. Hennepin County
Tyler v. Hennepin County, 598 U.S. 631 (2023)
- Court
- Supreme Court of the United States
- Decided
- 2023-05-25
- Docket
- 22-166
What happened
Geraldine Tyler, 94 years old, owed about $15,000 in property taxes on her Minneapolis condo. The county seized it, sold it for $40,000, and kept all of it.
What the court decided
The U.S. Supreme Court unanimously held that keeping the surplus beyond the tax debt is a taking of property without just compensation under the Fifth Amendment. A government may take what is owed, but not more.
In the court's words
“The taxpayer must render unto Caesar what is Caesar’s, but no more.”
Why it may matter to you
If your home was sold for taxes, the equity beyond what you owed belongs to you. Ask the county or court about "excess proceeds" and the deadline to claim them.
Why it might not apply
States set the procedure and deadlines for claiming surplus; missing them can cost you. Texas already has an excess-proceeds claim process (Tax Code § 34.04). In Pung v. Isabella County (2026) the Court held the surplus is measured by the sale price, not market value.
Most useful when
- Your home was sold for unpaid property taxes for more than you owed
- The government or buyer kept the extra money (the surplus)
How to cite it
The full citation for the first time you mention it, a short form for later, and a sample sentence you can adapt.
Tyler v. Hennepin County, 598 U.S. 631 (2023)Short formTyler, 598 U.S. 631Draft — check it with free legal aid before you file or say it in court.
In Tyler v. Hennepin County, 598 U.S. 631 (2023), the court held that a government that sells a home for unpaid taxes and keeps the value beyond the tax debt takes property without just compensation. Here, [say in one sentence what happened in your case]
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Related cases
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Pung v. Isabella County
No. 25-95 (U.S. June 23, 2026) · Decided 2026
The Pung family owed about $2,242 in property taxes. Isabella County, Michigan, sold their home — assessed at $194,400 — for $76,008 at auction. Their representative argued they were owed the home's fair market value, not just the auction surplus.
Read the case - Homeowner wonPersuasive
Hall v. Meisner
51 F.4th 185 · Decided 2022
Michigan homeowners lost their homes over tax debts much smaller than the homes' value; the county transferred the homes and the owners got nothing for their equity.
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Jones v. Flowers
547 U.S. 220 · Decided 2006
Gary Jones moved out of his Arkansas house but kept paying the mortgage. When taxes went unpaid, the state mailed notice by certified mail; it came back unclaimed, and the state sold the house anyway.
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