The power to convey property for nonpayment of taxes can be validly exercised only by strict compliance with the relevant statutes and regulations. Frassetto v. Barry, 497 A.2d 109, 113 (D.C. 1985); Boddie v. Robinson, 430 A.2d 519, 522 (D.C. 1981); Watson v. Scheve, 424 A.2d 1089, 1092 (D.C. 1980). Thus, if the District fails to comply with the statute and regulations, the sale is invalid and must be set aside.
It is firmly established in this jurisdiction that the District of Columbia "may effect a valid conveyance of property for nonpayment of real estate taxes only by `strict compliance' with the tax sale statute and regulations." Boddie v. Robinson, 430 A.2d 519, 522 (D.C. 1981) (citations omitted). Strict compliance is required to "guard against the deprivation of property without due process of law," and because "it is the policy of the state to give the delinquent taxpayer every reasonable opportunity, compatible with the rights of the state, to redeem his property."
We have stated on a number of occasions that "the District may effect a valid conveyance of property for nonpayment of real estate taxes only by 'strict compliance' with the tax sale statute and regulations." Boddie v. Robinson, D.C.App., 430 A.2d 519, 522 (1981) (citing Watson v. Scheve, D.C.App., 424 A.2d 1089, 1092 (1980); Shenandoah Corp. v. Pringle, D.C.App., 385 A.2d 748, 749 (1978); and Potomac Building Corp. v. Karkenny, D.C.App., 364 A.2d 809, 812 (1976) (per curiam), cert. denied, 431 U.S. 921, 97 S.Ct. 2192, 53 L.Ed.2d 234 (1977)). Indeed, the purchaser at a tax sale "acts at his peril, for deficiencies in notice publication are readily discoverable by him before he acts to purchase." Potomac Building Corp., 364 A.2d at 812.
The District, for its part, may effect a valid conveyance of property for nonpayment of real estate taxes only by strict compliance with the statutes and regulations that govern tax sales. Boddie v. Robinson, 430 A.2d 519, 522 (D.C. 1981). "If the District fails to comply in every respect with the statute and regulations, the sale is invalid and must be set aside." Associated Estates, LLC v. Caldwell, 779 A.2d 939, 943 (D.C. 2001) (citing Keatts v. Robinson, 544 A.2d 716, 719 (D.C. 1988)).
II. Neither side disputes the general principle that District of Columbia law requires strict compliance with the statutes and regulations governing tax sales of real property. Keatts v. Robinson, 544 A.2d 716, 719 (D.C. 1988); Frassetto v. Barry, 497 A.2d 109, 113-14 (D.C. 1985); Robinson v. Kerwin, 454 A.2d 1302, 1306 (D.C. 1983); Boddie v. Robinson, 430 A.2d 519, 522-23 (D.C. 1981); Shenandoah Corp. v. Pringle, 385 A.2d 748, 749-50 (D.C. 1978); Potomac Bldg. Corp. v. Karkenny, 364 A.2d 809, 812 (D.C. 1976), cert. denied, 431 U.S. 921, 97 S.Ct. 2192, 53 L.Ed.2d 234 (1977). The issue here is whether that rule prohibits a deviation, in the form of an abbreviated first name, from the full name of the property owner listed in the District's tax records when the government publishes or mails the required notices during the tax sale process.
"[T]he District may effect a valid conveyance of property for nonpayment of real estate taxes only by 'strict compliance' with the tax sale statute and regulations." Boddie v. Robinson, 430 A.2d 519, 522 (D.C. 1981) (citations omitted); accord, Frassetto v. Barry, supra, 497 A.2d at 113. Strict compliance is required "in order to guard against the deprivation of property without due process of law."
We have repeatedly warned that, " 'in order to guard against the deprivation of property without due process of law,' . . . the District may effect a valid conveyance of property for nonpayment of real estate taxes only by 'strict compliance' with the tax sale statute and regulations." Boddie v. Robinson, 430 A.2d 519, 521-22 (D.C. 1981) (quoting Potomac Building Corp. v. Karkenny, 364 A.2d 809, 812 (D.C. 1976) (per curiam), cert. denied, 431 U.S. 921, 97 S.Ct. 2192, 53 L.Ed.2d 234 (1977)); accord Robinson v. Kerwin, 454 A.2d at 1306; Watson v. Scheve, 424 A.2d 1089, 1092 (D.C. 1980); Shenandoah Corp. v. Pringle, 385 A.2d 748, 749-50 (D.C. 1978); Coleman v. Scheve, 367 A.2d 135, 138 (D.C. 1976). In 1819, Congress imposed a requirement that written reports of tax sales be filed with the Recorder of Deeds. Act of Feb. 20, 1819, ch. 35, § 2, 3 Stat. 486; King v. District of Columbia, 11 D.C. (MacArth. M.) 36, 40 (1879).
"Service by [regular] mail is reasonably calculated to give notice in most circumstances." Coleman v. Scheve , 367 A.2d 135, 137 n.1 (D.C. 1976) ; see Boddie v. Robinson , 430 A.2d 519, 521 n.4 (D.C. 1981) ("Notice by mail generally satisfies due process demands."). Posting notice on the property in conjunction with mailing "affords an additional measure of notification."
Rose, however, invokes our line of cases which have applied a doctrine of strict compliance to defects in the nonjudicial foreclosure process and in the closely analogous situation of tax sales. In Boddie v. Robinson, 430 A.2d 519 (D.C.1981), we invalidated a tax sale in which the notice contained the wrong quadrant address (S.W. for N.W.) even though the post office properly delivered the letter. A few years later, we invoked the Boddie principle in invalidating a nonjudicial foreclosure where the bank had failed to send the notice by certified mail as the statute required, without regard to whether the owner had actual notice of the upcoming sale.
04(d) (2001) because the document assigning the lien to Breen Capital Services Corporation failed to state Heyward's name and the dollar amount due, including penalties and interest. Finally, relying on Boddie v. Robinson, 430 A.2d 519, 523 (D.C. 1981), the trial court determined that the lien was void because Crusader failed to notify Heyward of his statutory right to redeem his property, in that the notice was sent to the wrong address. Both chapters allow the District to sell real property with outstanding liens at a public auction, but the property owner must be notified of the delinquency.