No. 25-95October Term 2025Decided Jun 23, 2026Updated Sep 2, 2026
Michael Pung, Personal Representative of the Estate of Timothy Scott Pung v. Isabella County, Michigan
The Court's decision sets the constitutional rules for this tax-foreclosure dispute involving a $2,241 debt.
Case status
Decided 9-0 · June 23, 2026 · Opinion by Justice Alito
Read the opinion (PDF)- Current stage
- Decided
- Latest event
- Decision released Jun 23, 2026
- What it's about
The Court unanimously vacated and remanded, holding that after a fairly conducted tax-foreclosure sale, the Fifth Amendment measures just compensation by the auction sale price rather than the property’s estimated open-market value. It also rejected the estate’s claim that paying only the auction surplus, rather than the property’s estimated market value, violated the Eighth Amendment’s Excessive Fines Clause.
Question presented
1. When the government takes property for tax debt, does the Fifth Amendment require compensation based on the property’s true fair market value, or only on the lower amount it sold for at a tax foreclosure auction? 2. Does the Eighth Amendment’s Excessive Fines Clause prohibit the government from seizing and keeping a property worth far more than the small tax debt owed on it?
- Case path
United States Court of Appeals for the Sixth Circuit / Decision released Jun 23, 2026
- Area
Business and Regulation
Decision
What the Court decided
The Court's decision sets the constitutional rules for this tax-foreclosure dispute involving a $2,241 debt.
- Result
- Vacated
Impact
A tax foreclosure auction (public sale to collect unpaid taxes) affects property owners. Former owners receive surplus proceeds (money remaining after tax debt), not hypothetical fair market value. The Pung home sold for $76,008 after $2,241.93 in taxes were owed. The rule applies when a tax sale is fairly conducted. Questions about adequate sale procedures remain on remand (sent back for further proceedings).
Not official Court text.
Vote
- Vote split
- 9-0
- Majority author
- Samuel A. Alito, Jr.
Majority
- Samuel A. Alito, Jr.(author)
- John G. Roberts, Jr.
- Elena Kagan
- Neil Gorsuch
- Brett M. Kavanaugh
- Amy Coney Barrett
- Ketanji Brown Jackson
- Clarence Thomas(concurring, author)
- Sonia Sotomayor(concurring, author)
Opinion documents
Briefing
What it's about
The Supreme Court decided a challenge to Isabella County's tax foreclosure of property after the Pung family owed $2,241 in taxes. The case concerned whether compensation must reflect fair market value or the auction price, and whether keeping property far more valuable than the debt is an excessive fine.
Vote
Impact
The decision affects homeowners whose property is sold over small unpaid tax debts and counties that conduct tax foreclosures. For example, it guides what a homeowner may receive when a tax sale brings more than the debt.
What's next
Lower courts and local tax agencies must apply the Supreme Court's decision in similar foreclosure cases. The parties may now pursue any further proceedings needed to carry out the decision.
What did the Supreme Court rule in Pung v. Isabella County?
The Court decided the constitutional dispute over tax foreclosure, property value, and a $2,241 tax debt. The decision now governs this case.
Who is affected by the Pung decision?
Homeowners facing tax foreclosure and local governments collecting overdue property taxes are affected. The case concerns what happens when property is worth far more than the debt.
What happens next in Pung v. Isabella County?
Lower courts and tax agencies must apply the Supreme Court's decision. The parties can take further steps needed to implement it.
Timing
Decided June 23, 2026
The Court released its decision 118 days after oral argument on February 25, 2026. The median for cases argued in February is 106 days.
Documents
Opinions
Samuel A. Alito, Jr.
Audio
Key filings
Briefs on file: 37View on supremecourt.gov
Activity
Docket activity7
AI analysis generated: Case Briefing
Sep 2, 2026 | Generated
AI analysis generated: Impact Analysis
Sep 2, 2026 | Generated
AI analysis generated: Opinion Summary
Sep 2, 2026 | Generated
Opinion added: Opinion of the Court - A
Jun 23, 2026 | Court records
Brief added: Questions Presented
Mar 8, 2026 | Court records
Audio Recording added: Oral Arguments - Pung
Feb 25, 2026 | Court records
Brief added: Petition
Jul 22, 2025 | Court records
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Sep 2, 2026
- Method
- Methodology
Primary materials10
Supreme Court docket 25-95
docket | Sep 3, 2026
Primary case document
Supreme Court document | Sep 3, 2026
Opinion of the Court (Samuel A. Alito, Jr.)
opinion | Jun 23, 2026
Questions Presented
brief | Mar 8, 2026
Oral argument
audio | Feb 25, 2026
Petition
brief | Jul 22, 2025
SupremeCourt.gov
official | Sep 2, 2026
SupremeCourt.gov
official | Sep 2, 2026
SupremeCourt.gov
official | Sep 2, 2026
SupremeCourt.gov
official | Sep 2, 2026