Rhode Island General Laws

R.I. Gen. Laws § 44-9-24 (2026)

Title absolute after foreclosure of redemption — Jurisdiction of proceedings

✓ current as of July 2026
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The title conveyed by a tax collector’s deed shall be absolute after foreclosure of the right of redemption by decree of the superior court as provided in this chapter. Notwithstanding the rules of civil procedure or the provisions of chapter 21 of title 9, no decree shall be vacated except in a separate action instituted within six (6) months following entry of the decree and in no event for any reason, later than six (6) months following the entry of decree. Furthermore, the action to vacate shall only be instituted for inadequacy of notice of the petition amounting to a denial of due process or for the invalidity of the tax sale because the taxes for which the property was sold had been paid or were not due and owing because the property was exempt from the payment of such taxes. The superior court shall have exclusive jurisdiction of the foreclosure of all rights of redemption from titles conveyed by a tax collector’s deed, and the foreclosure proceedings shall follow the course of equity in a proceeding provided for in §§ 44-9-25 — 44-9-33.

Notes of Decisions
Cited in 25 cases (5 in the last 5 years), 1974–2024 · leading case: Jeanne E. Johnson v. QBAR Assocs., 78 A.3d 48 (R.I. 2013).
Jeanne E. Johnson v. QBAR Assocs., 78 A.3d 48 (R.I. 2013). · cites it 13× “In pertinent part, G.L.1956 § 44-9-24 states: "the action to vacate shall only be instituted for inadequacy of notice of the petition amounting to a denial of due process or for the invalidity of the tax sale because the taxes for which the property was sold had been paid or…”
Sycamore Props., LLC v. Tabriz Realty, LLC, 870 A.2d 424 (R.I. 2005). · cites it 10× “At the hearing held on July 9, 2003, plaintiff argued that G.L.1956 § 44-9-24, as amended by P.L. 2002, ch.”
Mortg. Elec. Reg. Sys., Inc. v. Verissimo DePina, 63 A.3d 871 (R.I. 2013). · cites it 20× “The defendant contends, rather, that the Superior Court misconstrued G.L.1956 § 44-9-24 2 and that, under §§ 44-9-30 and 44-9-31 the plaintiffs are barred from redeeming the property and from raising defects in the tax sale and foreclosure proceedings.”
ABAR Assocs. v. Luna, 870 A.2d 990 (R.I. 2005). · cites it 7× “In addition, First Union counters ABAR’s argument that it should have filed a separate action in Superior Court by asserting that the version of § 44-9-24 in effect at the time this case was decided did not require a separate action to be filed and that there is conflicting case…”
John Izzo v. Victor Realty, 132 A.3d 680 (R.I. 2016). · cites it 3× “The plaintiffs, filed the complaint commencing the instant case on September 9, 2013, pursuant to § 44-9-24. 3 They *683 sought entry of an order vacating the final decree of August 9, 2013, which had foreclosed their rights of redemption; due to what they alleged was iñadequaté…”
Pleasant Mgmt., LLC v. Carrasco, 960 A.2d 216 (R.I. 2008). · cites it 3× “Furthermore, we held that § 9-21-2 rather than G.L.1956 § 44-9-24 provided the procedural grounds for vacating the default decree because: "Although the statute references foreclosing redemption rights generally, it does not expressly mention the foreclosure of rights of…”
Pleasant Mgmt., LLC v. Carrasco, 870 A.2d 443 (R.I. 2005). · cites it 4× “Furthermore, we hold that § 9-21-2, rather than the more narrow G.L.1956 § 44-9-24, provides the procedural grounds for vacating the default decree in this case.”
United Lending Corp. v. City of Providence, 827 A.2d 626 (R.I. 2003). “The plaintiff correctly contends that, once the city obtained title to the property by a foreclosure proceeding in accordance with § 44-9-24, property taxes no longer accrued.”
Pollard v. Acer Grp., 870 A.2d 429 (R.I. 2005). “2005), that, pursuant to § 44-9-24, as amended by P.L. 2002, ch. 140, §§ 1, 2 (effective January 7, 2003), a taxpayer’s right to bring a separate action to vacate a foreclosure decree is triggered by the entry of the foreclosure decree itself; and, therefore, the law in force on…”
Rachel Rafaelian v. Perfecto Iron Works, Inc., 68 A.3d 57 (R.I. 2013). · cites it 13× “Rafaelian argues that the trial justice ignored both Rule 81(a)(2) of the Superior Court Rules of Civil Procedure and G.L.1956 § 44-9-24, which precludes the Superior Court from vacating a final decree foreclosing the right of redemption after a tax sale.”
Burns v. Conley, 526 F. Supp. 2d 235 (D.R.I. 2007). · cites it 2× “Right of Redemption Plaintiffs assert that the Court should vacate the decree foreclosing their right to redemption pursuant to § 44-9-24 because they never received notice of the foreclosure petition.”
Driscoll v. Karroo Land Co., Inc., 600 A.2d 722 (R.I. 1991). · cites it 2× “…land until the expiration of one (1) year after the date of the sale.” 3 . Section 44-9-29. 4 . Section 44-9-25. 5 . Section 44-9-24.”
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.