New Jersey Statutes
N.J. Stat. § 54:5-9 (2026)
Municipal liens paramount
✓ current as of May 2026
Every municipal lien shall be a first lien on such land and paramount to all prior or subsequent alienations and descents of such lands or encumbrances thereon, except subsequent municipal liens.
Notes of Decisions
Cited in 13
cases (2 in the last 5 years), 1957–2026 · leading case: Cherokee LCP Land, LLC v. City of Linden Plan. Bd., 191 A.3d 597 (N.J. 2018).
Cherokee LCP Land, LLC v. City of Linden Plan. Bd., 191 A.3d 597 (N.J. 2018). “N.J.S.A. 54:5-9. For tax liens, "[a] subsequent tax sale certificate .”
Kolbe v. BAC Home Loans Servicing, LP, 695 F.3d 129 (1st Cir. 2012). “N.J. Stat. Ann. § 54:5-9 (West 2012). See generally Alexander, Tax Liens, Tax Sales, and Due Process, 75 Ind.”
Simon v. Cebrick, 53 F.3d 17 (1st Cir. 1995). “N.J.S.A. 54:5-9. Plaintiff requested that the FDIC consent to foreclosure of its lien interests in the Cebrick Property, and the FDIC refused.”
Hargrave v. Twp. of Pemberton (In Re Tabone, Inc.), 175 B.R. 855 (Bankr. D.N.J. 1994). “N.J.S.A. 54:5-9. The amounts indicated include trash charges, which are assessed in the same manner as property taxes, under N.”
Simon v. Cebrick, 53 F.3d 17 (3rd Cir. 1995). “N.J.S.A. 54:5-9. Plaintiff requested that the FDIC consent to foreclosure of its lien interests in the Cebrick Property, and the FDIC refused.”
Old Bridge Owners Coop. Corp. v. Twp. of Old Bridge, 914 F. Supp. 1059 (D.N.J. 1996). “54:5-9 exphcitly provides: Every municipal hen shall be a first hen on such land and paramount to ah prior or subsequent alienations and descents of such lands or encumbrances thereon, except subsequent municipal hens. N.J.S.A. 54:5-9. Language could not be more clear.”
Casino Reinvestment Dev. Auth. v. Teller, 894 A.2d 1215 (N.J. Super. Ct. App. Div. 2006). “N.J.S.A. 54:5-9; In re Pryor, 366 N.J.Super.”
Gline v. Horn & Co., P.C. (In Re Isley), 104 B.R. 673 (Bankr. D.N.J. 1989). “(N.J.S.A. 54:5-9.) The purpose of this system, as indicated by the legislative history, was to preserve the state’s right to collect the full amount of the taxes assessed upon particular pieces of property: Prior to a statutory amendment in 1944, property taxes did not become a…”
Kolbe v. BAC Home Loans Servicing, LP, 695 F.3d 111 (1st Cir. 2012). “N.J. Stat. Ann. § 54:5-9 (West 2012). See generally Alexander, Tax Liens, Tax Sales, and Due Process, 75 Ind.”
United States v. Ringwood Iron Mines, Inc., 151 F. Supp. 421 (D.N.J. 1957). “N.J.S.A. § 54:5-9. “Every municipal lien shall be a first lien on such land and paramount to all prior or subsequent alienations and descents of such lands or encumbrances thereon, except subsequent municipal liens.”
In Re Lieb Bros., Inc., 150 F. Supp. 68 (D.N.J. 1957). “Justice Minton, speaking for a unanimous court, held that the mortgage claim must come first and thereafter claims are to be validated in accordance with the principle, “first in time is the first in right” where there is no question of insolvency.”
Fulton Bank, Na v. Apple Mountain Rec. Inc. (N.J. Super. Ct. App. Div. 2025). “" The court stated "a municipal tax lien had priority over a mortgage lien even though the mortgage was prior in time" and noted the "the so-called super-priority of municipal tax liens" under N.J.S.A. 54:5-9 provided "[e]very municipal lien shall be a first lien on such land…”
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