Tyler and the Future of Tax Foreclosure in New Jersey

Date: Feb 29, 2024 9:00 a.m. – 10:40 a.m.

Location: Online

Member Price: $99

Non-Member Price: $125

Event Code: I144424

Areas of Law: Real Property, Trust, & Estate, Taxation

Earn up to 2 credits! (More Information)




Keith A. Bonchi, Esq.
General Counsel, Tax Collectors & Treasurers Association of New Jersey
Goldenberg, Mackler, Sayegh, Mintz, Pfeffer, Bonchi & Gill, Northfield


Elliott J. Almanza, Esq.
Goldenberg, Mackler, Sayegh, Mintz, Phiffer, Bonchi & Gill, Northfield
is a Partner in Goldenberg, Mackler, Sayegh, Mintz, Pfeffer, Bonchi & Gill in Northfield, New Jersey. With the firm since 2015, he focuses his practice in municipal liens.

Admitted to practice in New Jersey and Pennsylvania (inactive), Mr. Almanza has briefed and argued cases before the New Jersey Supreme Court, the Bankruptcy Court of New Jersey, the United States District Court for the District of New Jersey and the Third Circuit Court of Appeals. Prior to joining the firm he was an Assistant Prosecutor in the Atlantic County Prosecutor’s Office.

Mr. Almanza received his B.A. and B.S. from Rutgers University, where he was President of the Rutgers University Academic Team, and his J.D., cum laude, from Rutgers School of Law-Camden, where he was Vice President of the Immigration Law Society and the recipient of the 2012 Blaine E. Capehart Legal Writing Award, the 2011 Mary Philbrook Public Interest Award and several other honors. He clerked for the Honorable Raymond A. Batten, P.J.Ch. (Atlantic/Cape May vicinage) and the Honorable William A. Nugent, J.A.D.
Maryann Flanigan Sutherland, Esq.
Supervising Attorney, Foreclosure Defense Project, Legal Services of New Jersey, Edison
Robin London-Zeitz, Esq.
Law Offices of Gary C. Zeitz, LLC, Voorhees
Ira J. Metrick, Esq.
Ira J. Metrick Attorney At Law, LLC, Freehold

This seminar will focus on the impact of the United States Supreme Court decision in Tyler v Hennepin County, 598 US 631(2023) on tax sale foreclosures in the state of New Jersey. The panelists will review how the New Jersey courts have reacted to this decision and how the court rules have been revised. The panelists will review post Tyler decisions in New Jersey as well as New Jersey legislation and pending Bills.

Join us for an up to the minute discussion of:

  • The Tyler decision and preventing windfalls to tax foreclosure certificate holders;
  • Application of the case holding to New Jersey;
  • July 2023 Court Notice and Order (1) Suspending Office of Foreclosure Recommendations of Final Judgment and (2) Relaxation of Court Rules – In Response to U.S. Supreme Court Decision in Tyler v. Hennepin County;
  • Is there a difference if the tax foreclosed property in question is residential or commercial?;
  • Is there a difference if a party is a government entity or a private entity?;
  • How may value of a property be impacted?;
  • What is the impact on investors interested in buying tax foreclosure properties?;
  • What is the impact on tax sales certificate holders?; and
  • What revisions may be on the horizon for New Jersey tax foreclosure?

CLE Credits
NJ CLE:NJ CLE information: This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 2 hours of total CLE credit (Full Credits Available: CPE Taxation: 2.0, NJ General: 2.0).
NY CLE (t&nt):NY Professional Practice Non-Transitional: 2.0
PA CLE:PA Substantive Credit: 1.5
New: No PACLE fee is required for this program. To earn PA CLE credits, a valid PA Bar ID number must be entered into the CLE form provided after attending the program.

Important Information About Our Events, Meetings, and More:
To secure your spot and receive important updates about our events, meetings, and other gatherings, such as schedule changes, remember to register in advance.

Cancellation and Refund Policy:
If you need to cancel your registration and are not transferring to another program or date, please submit a written request to us at least three business days before the event, meeting, or gathering. You will receive a refund minus a $20.00 cancellation fee. No refunds or registration changes will be issued within three business days of the event, meeting, or gathering.

Stay Informed:
Registered participants will be notified of any schedule changes. For updates regarding inclement weather, please check your email or visit NJSBA.com.

Media Consent:
By participating in our events, meetings, or other gatherings, you agree to be photographed and/or recorded. Additionally, all media content captured during these gatherings will become the property of NJSBA. This content, including your image and name, may be used in our future promotional materials without additional consent or compensation.

Scholarship & Financial Assistance Policy:
Read our Scholarship & Financial Assistance Policy and submit an Application here: https://njsba.com/njicle/cle-programs/scholarship/


You do not have permission to view this form.