Citation Alert – OH Supreme Court

The Ohio Supreme Court recently quoted extensively from a University of Cincinnati Law Review article.  See  PHH Mtge. Corp. v. Prater, 133 Ohio St.3d 91, 2012-Ohio-3931 (Sept. 6, 2012), at ¶ 16.  The quoted excerpt and citation is provided below:

In some ways, the Internet already serves as a means of notification for tax foreclosure respondents. * * * Many of these newspaper websites have internal search engines that allow users to search for key terms; they need only to be told what to look for.  Nevertheless, web publication of legal notices, even if fully searchable, presumes a great deal of effort from the respondents in seeking information from the Internet about the viability of their claims to a property.  Even if a vigilant land interest holder could search all the relevant newspapers using one search engine, these inquiries would have to be renewed again and again to find important notices in time to act on them.  (Footnotes omitted.)

James J. Kelly Jr., Bringing Clarity to Title Clearing: Tax Foreclosure and Due Process in the Internet Age, 77 U. Cin. L. Rev. 63,113 (2008).

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