opinion: PEARSON v. DODD et al.
  No. 75-1318.
  Argued December 1,1976
  Decided January 12, 1977
  Philip G. Terrie argued the cause and filed briefs for appellant.
  Wrn. Roy Rice argued the cause for appellees. With him on the brief were John D. Daly and Thomas E. Morgan.
  Chauncey H. Browning, Jr., Attorney General, Jack C. McClung, Deputy Attorney General, and C. Page Hamrick III, Assistant Attorney General, filed a brief for the State of West Virginia as amicus curiae urging affirmance.
  Per Curiam.
  When appellant failed to pay 1961 real estate taxes pertaining to her one-quarter interest in the oil and gas in 68 acres of land in Kanawha County, W. Va., the interest became subject to transfer to the State under West Virginia statutory procedures that afford notice to the landowner only through the posting of a delinquency list on the county courthouse door and the publication of the list in local newspapers. W. Va. Code §§ HA-2-10a, 11A-3-2 (1974). The interest was sold to the State under these procedures in 1962. West Virginia Code § 11A-3-8 (1974) gave appellant a statutory entitlement to redeem the interest at any time within 18 months of the date of the state purchase, but appellant did not redeem during that period. The State thereafter decided to sell the interest and, as required by West Virginia law, commenced a suit in State Circuit Court to effect a sale. The suit resulted in the conveyance in 1966, by tax deed, of the oil and gas interest to appellee W. P. Dodd. The only notice of this sale was by way of publication in two local newspapers, pursuant to § 11A-4-12 (1974). Over two years later, in July 1968, appellant attempted to pay the State Auditor a sum of money to redeem the interest. Appellant then brought this action in state court to quiet title. The Circuit Court rendered judgment for appellees. The West Virginia Supreme Court of Appeals affirmed,-W. Va.-, 221 S. E. 2d 171 (1975). We noted probable jurisdiction. 426 U. S. 946 (1976).
  The Jurisdictional Statement phrased the due process question presented by the appeal as whether notice by publication of the tax sale was constitutionally deficient, but was unclear whether the challenge was directed to the 1962 sale to the State or to the 1966 sale to appellee Dodd. At oral argument counsel for appellant made clear, however, that her challenge was not addressed to the procedures for notice attending the 1962 transfer of the interest to the State, Tr. of Oral Arg. 21-23, but solely to the procedures for notice attending the 1966 sale of the interest by the State to appellee Dodd. Indeed, we were repeatedly informed that the 1962 sale to the State was not even “an issue in this case.” Id., at 22, 25,. 26. But under state law absolute title had vested in the State at the expiration of the 18-month period after the 1962 sale during which appellant might have exercised but did not exercise her Tight to redeem: § 11A-A-12 expressly provides that in such circumstance “the State has absolute title to all . . . land sold to the State for nonpayment of taxes . . . [which has] become irredeemable . . . Appellant thus has no constitutionally protected property or entitlement interest upon which she may base a challenge of constitutional deficiency in the notice provisions attending the 1966 sale to appellee Dodd. The appeal is therefore dismissed for want of a properly presented federal question.
  So ordered.
choices: comity: civil rights comity: criminal procedure comity: First Amendment comity: habeas corpus comity: military comity: obscenity comity: privacy comity: miscellaneous comity primarily removal cases, civil procedure (cf. comity, criminal and First Amendment); deference to foreign judicial tribunals assessment of costs or damages: as part of a court order Federal Rules of Civil Procedure including Supreme Court Rules, application of the Federal Rules of Evidence, Federal Rules of Appellate Procedure in civil litigation, Circuit Court Rules, and state rules and admiralty rules judicial review of administrative agency's or administrative official's actions and procedures mootness (cf. standing to sue: live dispute) venue no merits: writ improvidently granted no merits: dismissed or affirmed for want of a substantial or properly presented federal question, or a nonsuit no merits: dismissed or affirmed for want of jurisdiction (cf. judicial administration: Supreme Court jurisdiction or authority on appeal from federal district courts or courts of appeals) no merits: adequate non-federal grounds for decision no merits: remand to determine basis of state or federal court decision (cf. judicial administration: state law) no merits: miscellaneous standing to sue: adversary parties standing to sue: direct injury standing to sue: legal injury standing to sue: personal injury standing to sue: justiciable question standing to sue: live dispute standing to sue: parens patriae standing standing to sue: statutory standing standing to sue: private or implied cause of action standing to sue: taxpayer's suit standing to sue: miscellaneous judicial administration: jurisdiction or authority of federal district courts or territorial courts judicial administration: jurisdiction or authority of federal courts of appeals judicial administration: Supreme Court jurisdiction or authority on appeal or writ of error, from federal district courts or courts of appeals (cf. 753) judicial administration: Supreme Court jurisdiction or authority on appeal or writ of error, from highest state court judicial administration: jurisdiction or authority of the Court of Claims judicial administration: Supreme Court's original jurisdiction judicial administration: review of non-final order judicial administration: change in state law (cf. no merits: remand to determine basis of state court decision) judicial administration: federal question (cf. no merits: dismissed for want of a substantial or properly presented federal question) judicial administration: ancillary or pendent jurisdiction judicial administration: extraordinary relief (e.g., mandamus, injunction) judicial administration: certification (cf. objection to reason for denial of certiorari or appeal) judicial administration: resolution of circuit conflict, or conflict between or among other courts judicial administration: objection to reason for denial of certiorari or appeal judicial administration: collateral estoppel or res judicata judicial administration: interpleader judicial administration: untimely filing judicial administration: Act of State doctrine judicial administration: miscellaneous Supreme Court's certiorari, writ of error, or appeals jurisdiction miscellaneous judicial power, especially diversity jurisdiction