United States Lawsuit to Quiet Its Title to Land It Owned
In United States v. Alabama, 313 U.S. 274, 61 S. Ct. 1011, 85 L. Ed. 1327 (1941), the United States brought an action to quiet its title to land it owned in Alabama.
The state had asserted tax liens on the land prior to the United States' acquisition and had conducted proceedings for the sale of the land for delinquent taxes after the United States became the owner; the United States asserted that both the tax liens and the tax sale were invalid.
The United States Supreme Court held that the state's prior inchoate tax liens were valid against successors in title; however, with respect to the tax sale, the court stated as follows:
The proceedings in the county court for the sale of the lands were taken and the decrees were rendered after the United States had become the owner of the tracts.
A proceeding against property in which the United States has an interest is a suit against the United States.
The United States was an indispensable party to proceedings for the sale of the lands, and in the absence of its consent to the prosecution of such proceedings, the county court was without jurisdiction and its decrees, the tax sales and the certificates of purchase issued to the State were void. Alabama, 313 U.S. at 282.