In re Foreclosure of Liens for Delinquent Taxes

Appellant challenges the notice provisions for tax lien foreclosures embodied in R. C. 5721.18(B) on the basis that such provisions are facially violative of due *335process requirements imposed by the Fourteenth Amendment. Appellant also contends, in the alternative, that if the statute comports with due process, he was nonetheless denied his constitutional right to notice by the appellee’s failure to adhere to the statute. For reasons stated herein, we reject appellant’s first contention and agree with the second.

The statute in issue, R. C. 5721.18(B), provides, in its most pertinent parts, as…