In DJJ Investments v. Neldava, LLC, 2022 IL App (1st) 210815, the Illinois Appellate Court addressed an important issue in Illinois tax deed litigation: whether an assignment of a tax certificate may be upheld through ratification, even where technical defects are alleged.
The case arose from a contested tax deed proceeding involving a historic 14-story hotel on Chicago’s West Side. The objector challenged the validity of the tax certificate assignment, while the purchaser argued that the assignment had been properly ratified, curing any alleged defects.
The Appellate Court affirmed the issued tax deed, holding that ratification is an independent and operative legal principle capable of validating an assignment notwithstanding technical irregularities. The court’s analysis clarified that ratification principles apply fully in the tax deed context, including where Illinois land trust protections are implicated.
The decision promotes finality and predictability in tax sale proceedings and has implications beyond tax deed litigation, informing ratification analysis in other areas of Illinois law.
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