OPINION
DITTER, District Judge.
I. Introduction
This suit challenges certain tax sales conducted in Delaware County, Pennsylvania, pursuant to the County Return Act, Act of May 29, 1931, P.L. 280, as amended, 72 P.S. § 5971a et seq. The primary constitutional challenges to the Act are that it violates due process: (1) by failing to provide for a prior judicial determination of alleged delinquent property taxes before the tax sale is conducted...
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