Delta Property Management v. Profile Investment, Inc., 87 So. 3d 765

Delta contested a tax deed after notice was mailed to an old address and returned undeliverable, leading to a sale to Profile.
Profile had sought a tax deed after Delta failed to redeem a 1997 tax certificate; notice listed Delta’s old address from the 1999 roll.
Clerk mailed notice to the old address; notice was undeliverable, and sale proceeded in September 2000.
Delta claimed the Clerk should have checked the latest assessment roll and updated Delta’s address before mailing, per Delta II rule.
The First District initially held law-of-the-case barred consideration of the updated-notice argument, then later decisions remanded for factual resolution.
The Florida Supreme Court reversed, holding Jones and Vosilla apply and the Clerk must take extra steps when certified mail fails, invalidating the tax deed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Law-of-the-case barred consideration of new notice issue?	Delta argues law-of-the-case does not bar undecided issues.	Profile argues the First District correctly applied the law-of-the-case doctrine.	Law-of-the-case does not bar undecided issues.
Is due process satisfied when certified mail is returned undeliverable without further steps?	Delta contends Jones/Vosilla require additional steps to notify.	Profile asserts statutory notice suffices without extra steps.	Clerk must take additional reasonable steps; notice was constitutionally deficient.
Did the Clerk have to consult the latest assessment roll to update Delta’s address?	Delta contends the Clerk should have checked the latest roll and updated address.	Profile argues the 2000 roll was unavailable or not required.	Jones/Vosilla require considering updated addresses when reasonably ascertainable; in this record, sufficient basis to remand for factual resolution.
Does proper notice invalidate the tax deed if steps were not taken after undelivered notice?	Delta asserts the deed is invalid due to inadequate notice.	Profile contends the deed remains valid under statutory notice requirements.	Tax deed invalid; clerk’s inaction after undelivered notice violated due process.

Jones v. Flowers, 547 U.S. 220 (U.S. Supreme Court 2006) (notice sent by certified mail returned undeliverable; requires additional steps)
Vosilla v. Rosado, 944 So.2d 289 (Fla. 2006) (clerks must notify titleholders when address is known to be incorrect)
Juliano, 801 So.2d 101 (Fla. 2001) (law-of-the-case limits; issues actually decided govern later stages)
Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (U.S. Supreme Court 1950) (due process and notice must be reasonably calculated to apprise interested parties)
U.S. Concrete Pipe Co. v. Bould, 437 So.2d 1061 (Fla. 1983) (law-of-the-case limited to issues actually decided on appeal)
Jones v. Flowers, 547 U.S. 220 (U.S. Supreme Court 2006) (see above (duplicate for emphasis of Jones holding))