Flag Boy Properties, LLC v. Elvetta M. Dickerson, the Unopened Succession of Stella Mitchell O'gwinn, and the Unopened Succession of Allen A. O'Gwinn, 291 So.3d 241

Property at 5016 Warrington Dr. originally owned by Allen and Stella O’Gwinn; both are deceased and their successions are named defendants.
Elvetta Dickerson purchased a tax-sale interest in 2007 and paid taxes through 2012; she stopped paying thereafter.
Flag Boy purchased a tax-sale certificate on April 12, 2016 for 2013–2015 taxes, obtaining a 98% tax-sale interest.
City mailed a pre-tax-sale notice Dec. 2, 2015 (certified mail); a certified-mail receipt signed “Elvetta Dickerson” was in the record; Flag Boy sent a Dec. 27, 2017 post-sale notice to three addresses.
Flag Boy filed an affidavit to quiet title (June 28, 2018) and a partition-by-lication petition (July 23, 2018); Dickerson filed an exception of no right of action (Dec. 12, 2018). Trial court granted the exception and dismissed the petition (Mar. 14, 2019).
On appeal, the court found statutory notice was satisfied, the redemptive period expired, title transferred 98% ownership to Flag Boy, and reversed and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Flag Boy had a right to seek partition by licitation after acquiring a tax-sale certificate	Flag Boy: redemptive period expired and required notice was given; tax-sale title converted to ownership (98%), making it a co-owner entitled to partition	Dickerson: she did not receive proper notice of the tax sale, so Flag Boy never obtained ownership and lacks standing to seek partition	Court held notice satisfied under statutes and "duly notified" standard; redemptive period expired; title vested 98% ownership in Flag Boy; trial court erred and case remanded

Gunasekara v. City of New Orleans through Munster, 243 So.3d 623 (La. App. 4 Cir. 2018) (exception-of-no-right-of-action reviewed de novo)
Cent. Properties v. Fairway Gardenhomes, LLC, 225 So.3d 441 (La. 2017) (explains tax-sale title is lien-based and converts to ownership after due notice and redemptive period)
J-W Power Co. v. State ex rel. Dept. of Revenue & Taxation, 59 So.3d 1234 (La. 2011) (exception of no right of action assumes petition states a cause of action)
Hood v. Cotter, 5 So.3d 819 (La. 2008) (defines function of exception of no right of action)
N. Clark, L.L.C. v. Chisesi, 206 So.3d 1013 (La. App. 4 Cir. 2016) (procedural guidance on exceptions)
Mendonca v. Tidewater Inc., 862 So.2d 505 (La. App. 4 Cir. 2003) (procedural authority on exception standards)