Revisiting the 2025 PA Supreme Court Decision on “Title Washing”

Last year, we reported on a Pennsylvania Supreme Court decision issued in the case of Commonwealth of Pennsylvania, Pennsylvania Game Commission v. Thomas E. Proctor Heirs Trust (see PA Supremes Important Decision for Landowners re “Title Washing”). The PA Supremes addressed a question from the Third Circuit Court of Appeals regarding whether a 1908 tax sale of an “unseated” (undeveloped) parcel of land, the Haines Warrant, constituted a “title wash” that divested the subsurface estate owners of their ownership interest. We need to revisit that case and its fallout.

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