Rhode Island General Laws

R.I. Gen. Laws § 44-9-35 (2026)

Errors and irregularities in proceedings

✓ current as of July 2026
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No tax title shall be held to be invalid by reason of any error or irregularity which is neither substantial nor misleading, whether the error or irregularity occurs in the proceedings of the collector or the assessors or in the proceedings of any other official or officials charged with duties in connection with the establishment of the tax title, or in the proceedings to foreclose the rights of redemption as set forth in §§ 44-9-25 — 44-9-33. Failure of notice under §§ 44-9-9, 44-9-10 and 44-9-11 may only be raised by a party who was not sent notice and, if failure of notice is proved, the collector’s sale shall be invalid only as to that party and no other.

Notes of Decisions
Cited in 7 cases, 1966–2013 · leading case: Mortg. Elec. Reg. Sys., Inc. v. Verissimo DePina, 63 A.3d 871 (R.I. 2013).
Mortg. Elec. Reg. Sys., Inc. v. Verissimo DePina, 63 A.3d 871 (R.I. 2013). · cites it 6× “” Finally, § 44-9-35 provides that “[n]o tax title shall be held to be invalid by reason of any error or irregularity which is neither substantial nor misleading * * *.”
Jeanne E. Johnson v. QBAR Assocs., 78 A.3d 48 (R.I. 2013). · cites it 3× “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.”
Murray v. Schillace, 658 A.2d 512 (R.I. 1995). · cites it 4× “1956 (1988 Reenactment) § 44-9-35 and thus does not invalidate plaintiffs tax title.”
Town of Jamestown v. Pennsylvania Co. for Banking & Trusts, 221 A.2d 821 (R.I. 1966). · cites it 4× “1956, §44-9-35, which provides that no tax title shall be invalid by reason of any error or irregularity which is neither substantial nor misleading, was applicable; and that respondent had not satisfied the court that it was ready to redeem the -property since it had failed to…”
Burns v. Conley, 526 F. Supp. 2d 235 (D.R.I. 2007). “See § 44-9-35 (“No tax title shall be held to be invalid by reason of any error or irregularity which is neither substantial nor misleading, whether the error or irregularity occurs in the proceedings of the collector or the assessors or in the proceedings of any other official…”
Rhodes Assocs. v. City of Woonsocket, 523 A.2d 878 (R.I. 1987). “However, the trial justice relied upon § 44-9-35, which provides that “[n]o tax title shall be held to be invalid by reason of any error or irregularity which is neither substantial nor misleading.”
Antuono v. Faraone, 263 A.2d 111 (R.I. 1970). “9 of title 44, the state-wide tax sales statute, may not rely on §44-9-35, which provides that a tax sale or a deed given thereunder shall not be vitiated by a minor error or irregularity committed by any official charged with the responsibility of conducting the sale.”
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.