Tyler and the Future of Tax Foreclosure in New Jersey

Category: Materials

Member Price: $16

Non-Member Price: $20

Product Code: MI144424

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

CLE Credits



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.
nAdmitted 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.
nMr. 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?


Founded in 1899, the NJSBA is the largest organization of attorneys, judges and legal professionals in New Jersey. At the core of our mission is improving the lives of our members, advancing the rule of law and serving as the voice of the profession. With 85 sections and committees, the NJSBA allows attorneys to benefit from being part of the most wide-reaching legal association in the state, while still cultivating expertise and building networks within specialized practice areas.



The New Jersey State Bar Association is committed to promoting and fostering a diverse and inclusive bar association. The Association recognizes that the broad concept of diversity includes race, ethnicity, gender, gender identity, sexual orientation, religion, age and disability. The NJSBA fosters and promotes an inclusive environment that gives value to the unique contributions of diverse individuals and organizations in all aspects of the Association.

Learn More


The NJSBA Legal and  Government Affairs Department serves as the liaison between NJSBA members and the state’s three branches of government.

News and Press Publications

Learn more about the accomplishments of the Association, its members and events from regular news updates, press releases, and our award-winning magazine.



Read the comments, reports, resolutions and Board of Trustee news from the state’s largest organization of lawyers, judges and legal professionals.


Statements and Positions

The NJSBA is the voice of the profession and takes public positions on a range of issues with the legal community and government officials. It also takes positions on legislation and files friend-of-the-court briefs on matters that impact the profession. 

Photo Galleries

Check out photos from recent NJSBA events.

View Photo Albums


The New Jersey Law Center is located at 1 Constitution Sq, New Brunswick, NJ, 08901. Need directions to the Law Center? Click on the button below to get started right away.

Contact NJSBA

NJSBA Contact Us Form
If you're looking for an attorney, click here for help.

If you cannot afford an attorney and have a civil matter, click here for Legal Services of New Jersey.

Looking for information about a specific lawyer? Contact the Lawyer’s Fund for Client Protection at 855-533-3863.

Have a complaint about a lawyer? Visit the Office of Attorney Ethics website. Select “Attorney Discipline” from the navigation bar for discipline of attorneys.

Contact Info

One Constitution Square
New Brunswick, NJ 08901

9 a.m. to 5 p.m., Monday - Friday

Fax 732-249-2815

Email us

Book Store

Authoritative. Comprehensive. The Industry Standard.

NJICLE legal treatises and books are written for New Jersey attorneys, by New Jersey attorneys. Our comprehensive library of books and treatises form the State’s most inclusive series of regionally focused legal materials. With titles covering virtually every aspect of New Jersey legislation, NJICLE is proud to be the professional development resource for the legal community.

You do not have permission to view this form.