Hovannisian

INTRODUCTION

Appellants and siblings Bryce D. Hovannisian and Lindsay E. Hovannisian purchased several properties at a tax sale in 2020 from the City of Fresno (the City), which is a respondent in this matter alongside the City of Fresno Code Enforcement Division, John Giannetta, and Oscar J. Garcia as the Fresno County Tax Collector. Prior to the tax sale, these properties were the subject of special assessments for nuisance abatement costs and unpaid penalties, pursuant to which the City recorded liens against the properties. The County of Fresno (the County), which collects taxes on behalf of the City, issued tax bills for the 2020–2021 tax period to appellants after their purchase. These bills included the special assessments for nuisance abatement imposed prior to the tax sale. Appellants sought to pay only the amount of the tax bills that did not include these special assessments, contending the tax sale had removed any liens for nuisance abatement and they were not responsible for these assessments, which caused the County to reject the payments. Appellants then sued the City and the County to quiet title to the properties, to which the City and the County demurred,…