Mennonite Board of Missions v. Adams

Mennonite Board of Missions (MBM) (defendant) sold property to Alfred Jean Moore, who mortgaged the property back to MBM for $14,000; the mortgage was recorded. Moore stopped paying property taxes without telling MBM, and Elkhart County began proceedings to sell the property for the unpaid taxes, giving notice by publication, courthouse posting, and mail to Moore only — not to MBM. Moore never told MBM either. The property was sold to Richard Adams (plaintiff) for $1,167.75. MBM learned of the sale two years later, after the redemption period had expired, with Moore still owing MBM over $8,000. Adams sued to quiet title; MBM argued it never received constitutionally adequate notice. The trial court and Indiana Court of Appeals held the notice given was constitutional.