Rhode Island General Laws

R.I. Gen. Laws § 44-9-31 (2026)

Contest of validity of tax title

✓ current as of July 2026
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If a person claiming an interest desires to raise any question concerning the validity of a tax title, the person shall do so by answer filed in the proceeding on or before the return day, or within that further time as may on motion be allowed by the court, providing the motion is made prior to the fixed return date, or else be forever barred from contesting or raising the question in any other proceeding. He or she shall also file specifications setting forth the matters upon which he or she relies to defeat the title; and unless the specifications are filed, all questions of the validity or invalidity of the title, whether in the form of the deed or proceedings relating to the sale, shall be deemed to have been waived. Upon the filing of the specifications, the court shall hear the parties and shall enter a decree in conformity with the law on the facts found.

Notes of Decisions
Cited in 24 cases (5 in the last 5 years), 1974–2024 · leading case: United Lending Corp. v. City of Providence, 827 A.2d 626 (R.I. 2003).
United Lending Corp. v. City of Providence, 827 A.2d 626 (R.I. 2003). · cites it 7× “As a result, pursuant to § 44-9-31, its right to contest the validity of the sale by the board and its right to redeem the property were forever barred.”
Kildeer Realty v. Brewster Realty Corp., 826 A.2d 961 (R.I. 2003). · cites it 8× “The plaintiff argues that § 44-9-31 operates as an absolute bar to vacating the judgment because defendant failed to comply with the provisions of § 44-9-29 by faffing to file an answer and an offer to redeem the property on or before the return day.”
Sycamore Props., LLC v. Tabriz Realty, LLC, 870 A.2d 424 (R.I. 2005). · cites it 6× “The crux of plaintiff’s argument was that, notwithstanding the language of § 44-9-31 3 requiring that any challenge to the validity of a tax sale be raised in the' foreclosure proceeding, his ability to contest the tax sale should not be lost.”
Norwest Mortg., Inc. v. Masse, 799 A.2d 259 (R.I. 2002). · cites it 3× “Section 44-9-31 provides that when contesting the validity of a tax sale, “the person shall do so by answer filed in the proceeding on or before the return day * * * or else be forever barred from contesting or raising the question in any other proceeding.”
John Izzo v. Victor Realty, 132 A.3d 680 (R.I. 2016). · cites it 2× “That statute provides, in pertinent part, as follows: “Once a petition is filed under § 44-9-25, and any party in interest entitled to notice of the tax sale receives actual notice of the pendency of the petition to foreclose, the party must raise the notice defense in…”
Karayiannis v. Ibobokiwe, 839 A.2d 492 (R.I. 2003). · cites it 4× “Further, any attack on the validity of the tax title by either defendant is untimely and henceforth is waived because neither answered the petition nor filed specifications “on or before the return day” as required by § 44-9-31. We deny and dismiss the appeals.”
Medeiros v. Bankers Trust Co., 38 A.3d 1112 (R.I. 2012). · cites it 5× “) Moreover, § 44-9-31 provides in pertinent part: “If a person claiming an interest desires to raise any question concerning the validity of a tax title, the person shall do so by answer filed in the proceeding on or before the return day, or within that further time as may on…”
Jeanne E. Johnson v. QBAR Assocs., 78 A.3d 48 (R.I. 2013). · cites it 2× “” Section 44-9-31. However, even when challenged — whether during or after redemption foreclosure proceedings — a tax sale or title may not be held to be invalid “by reason of any error or irregularity which is neither substantial nor misleading.”
Smith v. City of Providence, 828 A.2d 536 (R.I. 2003). · cites it 6× “” G.L.1956 § 44-9-31. Additionally, Smith contended that the city’s argument that its tax Ken merged with its fee title was without merit.”
Pleasant Mgmt., LLC v. Carrasco, 960 A.2d 216 (R.I. 2008). “General Laws 1956 § 44-9-31 provides in pertinent part: “If a person claiming an interest desires to raise any question concerning the validity of a tax title, the person shall do so by answer filed in the proceeding on or before the return day, * * * or else be forever barred…”
Albertson v. Leca, 447 A.2d 383 (R.I. 1982). “1956 (1980 Reenactment) § 44-9-31 precluded defendants from challenging the validity of the tax title because defendants had failed to file specifications before the return date and (2) that defendants were not entitled to redeem because they were incapable of restoring the real…”
140 Reservoir Avenue Assocs. v. Sepe Investments, LLC, 941 A.2d 805 (R.I. 2007). “The city cites § 44-9-31, which says: “Contest of validity of tax title.”
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