Sines v. Blaser, 100 Idaho 50

Defendants Blaser owned the subject Canyon County property with Ruth Blaser listed on title; property tax delinquency spanned 1967–1970; County Treasurer sent an informal delinquency notice in 1970 and a formal certified notice in August 1970; when notice by certified mail was unclaimed, publication followed and tax deed issued January 4, 1971; the deed was later conveyed to Sines on August 6, 1973; plaintiffs filed quiet title action in 1973 seeking to defeat Blasers' vendor’s lien; Blasers argued that notice failure voided the tax deed under I.C. § 63-1134; trial court held notices were properly issued and deed valid; appellate notice issues were raised regarding appeal, but the court proceeded to decide the substantive notice issue; the court held that when two record owners reside at the same address, a single notice to both is required; the Blasers must be given separate notice to each owner for the tax deed to be valid; the deed to Sines was void due to lack of required notice to Ruth L. Blaser; judgment reversed and remanded for proceedings consistent with the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there proper notice under I.C. § 63-1134 to both owners?	Blasers argue lack of separate notice to Ruth L. Blaser.	Sines contend single notice suffices when at same address.	Notice to both required; deed void for failure to notify Ruth.

Lawyer v. Sams, 72 Idaho 101, 237 P.2d 606 (Idaho Supreme Court 1951) (mandatory notice; lack of notice fatal to tax deed)
Johnson v. Welch, 48 Idaho 284, 281 P. 748 (Idaho Supreme Court 1929) (notice requirements strict; failure fatal)
Dickerson v. Hansen, 32 Idaho 18, 177 P. 760 (Idaho Supreme Court 1918) (notice invalid if not properly served)
Rice v. Rock, 26 Idaho 552, 144 P. 786 (Idaho Supreme Court 1914) (precedent on notice sufficiency)
Armstrong v. Jarron, 21 Idaho 747, 125 P. 170 (Idaho Supreme Court 1912) (early rule on notice to co-owners)