O.C.G.A.

O.C.G.A. § 48-4-41 (2019)

Redemption by creditor without lien

✓ O.C.G.A. — 2019 edition (Public.Resource.Org Release 73)
Code text and O.C.G.A. statutory annotations on this page reflect the 2019 Official Code of Georgia Annotated (Public.Resource.Org Release 73, 2019-08-21; public domain per Georgia v. Public.Resource.Org, 2020). The Syfert case-law annotations in Notes of Decisions, below, are current.
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If the property is redeemed by a creditor of the defendant in fi. fa. who has no lien, the creditor shall have a claim against the property for the amount advanced by him in order to redeem the property if: (1) There is any sale of the property after the redemption under a judgment in favor of the creditor; and (2) The quitclaim deed is recorded as required by law.

History

Ga. L. 1898, p. 85, § 4; Civil Code 1910, § 1171; Code 1933, § 92-8303; Code 1933,

§ 91A-432, enacted by Ga. L. 1978, p. 309, § 2.

Annotations

JUDICIAL DECISIONS Construction with other law. - O.C.G.A. § 48-4-41 provides that if

property that has been sold at a tax sale is redeemed by a creditor of the defendant in

fi. fa. who has no lien, the creditor has a claim against the property for the amounts advanced to redeem the property if there is any sale of the property after the redemption under a judgment in favor of the creditor. O.C.G.A. § 48-4-41 does not address, however, the priority of this claim and whether it constitutes a separate lien, which are matters addressed by O.C.G.A. § 48-4-43. United Capital Fin. of Atlanta, LLC v. Am. Inv. Assocs., 302 Ga. App. 400, 691 S.E.2d 272, 2010 Ga. App. LEXIS 139 (2010), overruled in part, DLT List, LLC v. M7VEN Supportive Hous. & Dev. Group, 335 Ga. App. 318, 779 S.E.2d 436, 2015 Ga. App. LEXIS 769 (2015). Interest acquired following redemption date. - Oral agreement to buy a homeowner’s association’s lien and indebtedness against real property was required to be in writing and signed by the party to be charged, pursuant to O.C.G.A. § 13-5-30(4); because the buyer did not

acquire an interest in the property until after the date of redemption, contrary to O.C.G.A. §§ 48-4-40 and 48-4-41, the redemption was void. DRST Holdings, Ltd. v. Brown, 290 Ga. 317, 720 S.E.2d 626, 2012 Ga. LEXIS 11 (2012). Failure to show property interest. - Trial court erred by granting summary judgment to appellee because the homeowners’ association’s assignment of a lien for unpaid association dues the association relied upon to show the association possessed a property interest that authorized the association’s redemption of the property indicated a different name than the property owners and the appellee had already obtained the excess tax sale funds based on the association’s asserted lien resulting from the redemption. Postell v. Trinitec Portfolio Svcs., LLC, 341 Ga. App. 283, 799 S.E.2d 597, 2017 Ga. App. LEXIS 181 (2017).

RESEARCH REFERENCES Am. Jur. 2d. 30 Am. Jur. 2d, Executions, § 499. C.J.S. 85 C.J.S., Taxation, § 1359. ALR. Rights or interests covered by quitclaim deed, 44 A.L.R. 1266; 162 A.L.R. 556.

Right of mortgagor or purchaser of equity of redemption to defeat lien of mortgage by acquisition of title at sale subsequent to mortgage for nonpayment of taxes, or of assessment for local improvement, 134 A.L.R. 289.

Notes of Decisions
Cited in 6 cases, 2010–2017 · leading case: United Capital Fin. of Atlanta, LLC v. Am. Inv. Assocs., Inc., 691 S.E.2d 272 (Ga. Ct. App. 2010).
United Capital Fin. of Atlanta, LLC v. Am. Inv. Assocs., Inc., 691 S.E.2d 272 (Ga. Ct. App. 2010). · cites it 10× “the property controlled for purposes of OCGA § 48-4-43, concluding that “the statutory scheme seems to be that a judgment[ ] or lienholder may redeem the property to create a super-lien, not that merely any creditor of the taxpayer may redeem the property to create a…”
DRST Holdings, Ltd. v. Brown, 720 S.E.2d 626 (Ga. 2012). · cites it 4× “at the time of the attempted redemption as required by OCGA § 48-4-41. Therefore, according to the trial court, the redemption of the property was void and thus could not support claims for money rule, mandamus, and other relief.”
La Chona, LLC v. Aberra, 797 S.E.2d 895 (Ga. 2017). · cites it 4× “or any person having any right, title, or interest in or lien upon such property may redeem” the property); OCGA § 48-4-41 (providing that a “creditor of the defendant in fi.”
Styles v. Spyke Ten, LLC, 802 S.E.2d 369 (Ga. Ct. App. 2017). · cites it 2× “’ OCGA § 48-4-41 authorizes redemption by ‘a creditor of the defendant in fi.”
La Chona, LLC v. Aberra (Ga. 2017). · cites it 4× “At some point before the tax deed was recorded, Forum IRA, LLC, (“Forum”), paid La Chona $48,000 to redeem the property.”
Postell v. Trinitec Portfolio Servs., LLC, 799 S.E.2d 597 (Ga. Ct. App. 2017). · cites it 2× “In Georgia, only certain persons are authorized to redeem property from a tax sale. OCGA § 48-4-40 authorizes redemption by the defendant in fi.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.