In February, the United States District Court for the Eastern District of Michigan issued its opinion in Metro T. Properties, LLC v. County of Wayne, No. 2:23-cv-11457-LVP-KGA, 2024 WL 644515 (E.D. Mich. Feb. 15, 2024). Few outside of Michigan likely reviewed the case upholding the constitutionality of Michigan’s General Property Tax Act (“GPTA”). Yet the implications for tax lien investors extend beyond Michigan because the opinion sheds light on the potential limitations of the Supreme Court’s decision in Tyler v. Hennepin County, No. 22-166 (May 25, 2023).[1]

As we discussed last year as guests on an episode of the Tax Sale Resources Podcast focused on the fallout of the Tyler case, our team identified Michigan as a state to watch because its courts were some of the first to interpret Tyler. This article explores how the reasoning in Metro T. Properties could be leveraged to confine the impact of Tyler to Minnesota alone, offering a nuanced perspective on the broader applicability of the Supreme Court's ruling to tax foreclosure statutes in other jurisdictions.

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