Skip to main content

No. 25-95October Term 2025Decided Jun 23, 2026Updated Sep 2, 2026

Docket 25-95October Term 2025 (2025–2026)

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
Case Accepted
Arguments HeardFeb 25, 2026
Decision ReleasedJun 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

Decision record

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.

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

Justice Alito wrote the 9–0 opinion, joined by Chief Justice Roberts and Justices Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson; Justices Thomas and Sotomayor concurred.

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.

Based on 28 merits cases argued in February since 1995.Argument and decision days

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