United States v. Winterburn

ALARCON, Circuit Judge:

The government appeals from the order of the district court denying the motion of the United States for summary judgment to foreclose federal tax liens against the interest of Stephen and Linda Winterburn in real property located in Whatcom County, Washington.

We must determine whether the judgment of a Washington state court terminating the Winterburns’ rights under a real estate sales contract was rendered in a quiet title action. Because we conclude that this proceeding was a quiet title action under Washington law, the district court’s order dismissing the action…