Krystalo Hetelekides, &c. v. County of Ontario

State of New York OPINION Court of Appeals This opinion is uncorrected and subject to revision before publication in the New York Reports. No. 3 Krystalo Hetelekides, &c., Appellant, v. County of Ontario et al., Respondents. Mary Jo S. Korona, for appellant. Jason S. DiPonzio, for respondents. Pacific Legal Foundation, amicus curiae RIVERA, J.: Two fundamental legal principles govern our decision in this appeal. First, a tax foreclosure proceeding is in rem against the “res”—the taxable real property—and not an action in personam commenced against an individual to establish personal…