SC20322 - Redding v. Georgetown Land Development Co., LLC (Foreclosure of municipal tax liens; "This appeal requires us to determine the priority of tax liens levied on real property by the Georgetown Special Taxing District (taxing district) pursuant to No. 07-196, § 4 (b) (3), of the 2007 Public Acts (P.A. 07-196) relative to tax liens held by other municipal entities on that same property. The plaintiffs, the town of Redding (town), the Redding Water Pollution Control Commission (commission), and Georgetown Fire District (fire district), brought this action to foreclose municipal liens against the defendant RJ Tax Lien Investments, LLC, an assignee of real estate tax liens originally levied by the taxing district. The town and the fire district filed motions for partial summary judgment with respect to priority, asserting that, under P.A. 07-196, § 4 (b) (3), their tax liens had priority over the liens that the defendant had acquired from the taxing district. The trial court agreed, granted their motions for partial summary judgment, and subsequently rendered a judgment of strict foreclosure in favor of the town and the fire district. The defendant appeals from the judgment of strict foreclosure, claiming that the trial court incorrectly concluded that its liens were subordinate to those of the town and the fire district. Although we agree with the trial court that the liens acquired by the defendant from the taxing district are subordinate to those of the town, we agree with the defendant that the trial court incorrectly concluded that they are subordinate to those of the fire district. Accordingly, we reverse the judgment insofar as the trial court granted the fire district's motion for partial summary judgment with respect to priority, and we remand the case with direction to vacate that portion of the judgment subordinating the liens acquired by the defendant to the fire district's liens, to render judgment consistent with this opinion, and for the setting of new law days.")