Pung v. Isabella County · ¶1

The Pung family owed $2,241.93 in real-property taxes, so local tax authorities in Isabella County, Michigan, initiated foreclosure proceedings and sold the Pung home—which was assessed at $194,400 for tax purposes—for $76,008 at public auction. Michael Pung sued in Federal court, and the District Court granted Pung partial summary judgment on his Fifth Amendment claim. The court held that Pung should receive only the surplus proceeds from the tax sale—i.e., the difference between the sale price and the tax debt—not the property’s fair market value. The District Court also rejected Pung’s claim under the Eighth Amendment Excessive Fines Clause. The Sixth Circuit affirmed.

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