Strict Foreclosure of a Land Contract

Legal information, not legal advice. Verify against the cited primary sources before acting. Contract-for-deed remedy law varies by jurisdiction and is frequently amended. Last verified: 2026-06-08.

• What it is: This page covers the treat-as-mortgage pole of forfeiture-vs-foreclosure: the states where a defaulted contract for deed (installment land contract) cannot be cancelled by forfeiture and must instead be foreclosed like a mortgage, with the buyer keeping an equity of redemption and a claim to any surplus from a sale. “Strict foreclosure” is used in two distinct senses, and the distinction matters:

  1. The genus — “foreclose, don’t forfeit.” Loosely, practitioners say a treat-as-mortgage state requires the seller to “foreclose” the contract: the seller’s retained legal title is recharacterized as a security lien (equitable mortgage), the buyer holds equitable title, and the buyer’s interest can be extinguished only by a court process that protects accumulated equity. This is the sense in which Indiana, Kentucky, Oklahoma, Florida, Nebraska, Idaho, New York and others “treat the contract as a mortgage.”
  2. The term of art — “strict foreclosure” proper. Technically, strict foreclosure is a specific mortgage remedy: a court decree that fixes a redemption period and, if the debtor does not pay within it, vests absolute title in the creditor with no sale and no surplus accounting. It is the mortgage analogue closest to forfeiture, and most states have abolished or restricted it in favor of foreclosure by judicial sale precisely because a no-sale decree strips the debtor’s equity. A handful of jurisdictions (notably Vermont and Connecticut) retain strict foreclosure as a procedure but gate it on a finding that the property has no value in excess of the debt — i.e., that there is no equity to protect.

• Why it matters for contract-for-deed: Whether a defaulted deal is forfeited or foreclosed is the single deal-defining question of land-contract law (see forfeiture-vs-foreclosure). In a treat-as-mortgage state the answer is fixed against forfeiture: the seller who wants to recover the land must file a foreclosure action, prove up the debt, and either sell the property (returning surplus to the buyer) or — only where there is no equity — take a strict (no-sale) decree. That changes everything downstream: timeline (months of litigation, not a 30–90-day mailed notice); cost (a judicial suit, often title-company and attorney-driven); the buyer’s redemption right (pre-sale equity of redemption plus, in many states, a statutory post-sale redemption period); and the seller’s deficiency exposure. A seller who tries to evict a defaulting buyer who is legally an equitable owner, or who relies on a self-executing forfeiture clause, will have the action dismissed and may forfeit the very equity the statute protects. This is also the live fault line of the CFPB / state-AG predatory-CFD enforcement wave: the practice regulators target is exactly forfeiting a substantially-paid buyer in a state where the law requires foreclosure.

• The two doctrinal sources of the rule: A state reaches “foreclose, don’t forfeit” by one of two routes:

  • Statute (deeming clause). A constructive-mortgage statute deems any instrument given to secure payment of money — expressly including a contract for deed — a mortgage subject to the same rules of foreclosure. Oklahoma (16 O.S. § 11A) and Florida (Fla. Stat. § 697.01) are the cleanest examples.
  • Case law (recharacterization). The state supreme court holds an installment land contract is, in substance, a purchase-money mortgage and bars forfeiture — either categorically (sebastian-v-floyd-1979, Ky.) or once the buyer has substantial equity (skendzel-v-marshall-1973, Ind.). New York, Idaho, Nebraska, Vermont, Alaska, and others follow this judicial route. A few states reach the same result by equitable conversion alone — the vendee is the equitable owner and the vendor’s title is security — so a defaulted contract is enforced in equity, not forfeited (New Jersey, gallicchio-v-jarzla-1952, backstopped by the anti-penalty rule of kutzin-v-pirnie-1991).

• Strict foreclosure proper vs. foreclosure by judicial sale: Within the treat-as-mortgage states, the remedy that actually runs on default depends on whether the buyer has equity in excess of the debt:

  • Equity exists → foreclosure by judicial sale. The property is sold, the seller is paid the unpaid balance/interest/costs from the proceeds, and the buyer takes any surplus. This is the mainstream outcome and the one that protects the substantially-paid buyer (Vermont 12 V.S.A. § 4945; the redemption- and-surplus model in Kentucky, Florida, Oklahoma, Nebraska, New York, Idaho).
  • No equity → strict (no-sale) foreclosure may be available. Where the property is worth no more than the debt, a court may decree foreclosure without a sale, vesting title in the seller after an unredeemed redemption period — because there is no surplus to return. Vermont codifies exactly this gate: a court “shall [not]” enter a decree foreclosing the right of redemption without sale “absent a finding … that there is no substantial value in the property in excess of the mortgage debt” (12 V.S.A. § 4941(c)). The no-equity gate is the modern law’s reconciliation of strict foreclosure with the anti-forfeiture principle: a no-sale decree is permissible only when forfeiting nothing.

• Leading authority: skendzel-v-marshall-1973 (Ind. — substantial-equity bar; foreclose like a mortgage with redemption) · sebastian-v-floyd-1979 (Ky. — forfeiture void as a matter of law; remedy is judicial sale) · Fla. Stat. § 697.01 and 16 Okla. Stat. § 11A (statutory deeming clauses) · 12 V.S.A. §§ 4941, 4945 (Vermont strict-foreclosure / judicial-sale framework; prue-v-royer-2013).

▸ For Sellers / Operators — If your jurisdiction is on the table below, assume a forfeiture clause is unenforceable and underwrite the deal as a foreclosure exit, not a cancellation. Concretely: (1) You must sue. There is no mailed-notice cancellation shortcut (contrast the statutory-cancellation states, minnesota / iowa / north-dakota); plan for a judicial foreclosure measured in months, with attorney and (often) title-company involvement. (2) You probably must sell. Where the buyer has equity, the court orders a judicial sale and the buyer keeps the surplus — you recover only your debt, interest and costs. A true strict (no-sale) foreclosure that lets you keep the land is available only where there is no equity to forfeit (e.g., Vermont’s § 4941(c) “no substantial value in excess of the debt” finding). (3) The buyer is an owner, not a tenant. Do not attempt an eviction or self-help repossession — the buyer holds an equity of redemption you must foreclose, and many states layer a post-sale statutory redemption period on top. (4) Mind deficiency and recording. Some states condition the foreclosure on the contract being recorded and mortgage tax paid (Oklahoma § 11A expressly) and allow a deficiency judgment (Nebraska). Classify your state before you draft, price, and reserve.

▸ For Buyers — In a treat-as-mortgage state your equity is structurally protected: the seller cannot keep your payments and retake the land by forfeiture. Your interest can be cut off only by a court foreclosure, you hold an equity of redemption (pay the balance and keep the property), and where the property is worth more than the debt the seller must sell and pay you the surplus. A strict, no-sale decree is permissible against you only when the property has no value above the debt — i.e., when you have no equity to lose.

Jurisdiction map

Positions are stated only where a retrieved primary source supports them. States not listed are not yet classified on this page (several are statutory-cancellation, hybrid, or strict-forfeiture jurisdictions handled in forfeiture-vs-foreclosure; the unclassified balance is in needs_verification). Per-state nuance lives on each [[state]] page; this table is the cross-jurisdiction index for the treat-as-mortgage / foreclose-like-a-mortgage position and the narrow survival of true strict (no-sale) foreclosure.

Position	Jurisdiction	Authority (primary source)
Treat-as-mortgage by statute — contract for deed “deemed and held [a] mortgage[],” subject to the “same rules of foreclosure”; no foreclosure unless recorded and mortgage tax paid	oklahoma	16 Okla. Stat. § 11A; Lucas v. Bishop, 1998 OK 16, 956 P.2d 871 — lucas-v-bishop-1998
Treat-as-mortgage by statute — any instrument to secure payment of money is “deemed and held to be a mortgage”; seller must foreclose the buyer’s equity of redemption (Ch. 702 judicial foreclosure)	florida	Fla. Stat. § 697.01
Treat-as-mortgage (case law, categorical) — forfeiture clause “not enforceable”; seller holds “bare legal title, as security”; remedy is a judicial sale	kentucky	Sebastian v. Floyd, 585 S.W.2d 381, 382–84 (Ky. 1979) — sebastian-v-floyd-1979; reaffirmed slone-v-calhoun-2012
Treat-as-mortgage (case law, substantial-equity bar) — vendor’s interest is a lien; a substantially-paid buyer must be foreclosed like a mortgagor with right of redemption, not forfeited	indiana	Skendzel v. Marshall, 301 N.E.2d 641, 646–50 (Ind. 1973) — skendzel-v-marshall-1973
Treat-as-mortgage (case law) — vendor “has the right to foreclose on the executory land contract as if it were a mortgage” and obtain a deficiency	nebraska	Porter v. Smith, 240 Neb. 928, 486 N.W.2d 846 (1992) — porter-v-smith-1992
Treat-as-mortgage (case law) — strict forfeiture of a land contract is a penalty; equity requires the contract be foreclosed and sold by judicial sale, surplus to the buyer	idaho	Thomas v. Klein, 99 Idaho 105, 577 P.2d 1153 (1978) — thomas-v-klein-1978
Treat-as-mortgage (case law) — defaulting vendee holds equitable title / equity of redemption; vendor must foreclose mortgage-style, not dispossess or enforce a forfeiture-of-payments clause	new-york	Bean v. Walker, 95 A.D.2d 70, 464 N.Y.S.2d 895 (App. Div. 1983) — bean-v-walker-1983
Treat-as-mortgage (case law) — vendee with substantial equity has an absolute right to redeem even after willful default; seller proceeds by quiet title subject to redemption, not forfeiture	california	Petersen v. Hartell, 40 Cal.3d 102, 707 P.2d 232 (1985) — petersen-v-hartell-1985
Treat-as-mortgage (case law) — installment contract enforced as an equitable mortgage once buyer has substantial equity; judicial sale and accounting	arkansas	classified case-law treat_as_mortgage (see arkansas)
Treat-as-mortgage (case law) — buyer holds equity of redemption; remedy is foreclosure with equitable limits on forfeiture	hawaii	Jenkins v. Wise, 58 Haw. 592, 574 P.2d 1337 (1978) — jenkins-v-wise-1978
Treat-as-mortgage (case law) — forfeiture disfavored/defeated; seller needs an enforceable foreclosure cutting off the buyer’s equity of redemption	alaska	classified case-law treat_as_mortgage (see alaska; AS 09.45.170)
Treat-as-mortgage (case law) — possessory vendee may not be forfeited; seller must judicially foreclose the equity	pennsylvania	classified case-law treat_as_mortgage (see pennsylvania)
Treat-as-mortgage (case law) — equity relieves the defaulting purchaser from a strict-forfeiture clause (penalty) and allows redemption; foreclose the equity of redemption (Master-in-Equity)	south-carolina	Lewis v. Premium Investment Corp., 351 S.C. 167, 568 S.E.2d 361 (2002) — lewis-v-premium-investment-corp-2002
Treat-as-mortgage (statute + case law) — defaulted contract foreclosed under the mortgage-foreclosure chapter with a court-set redemption window and equity-balancing	south-dakota	SDCL 21-50-1, 21-50-3; Heikkila v. Carver — heikkila-v-carver-1985
Treat-as-mortgage; protected residential case — residential installment contract foreclosed as a mortgage (judicial sale, 14 M.R.S. §§ 6321–6325) with a 60-day equity of redemption	maine	14 M.R.S. §§ 6321–6325 (judicial foreclosure / redemption)
Treat-as-mortgage (judicial-foreclosure state, equity route) — by equitable conversion the installment vendee is the equitable owner and the vendor holds legal title as security, so the interest is extinguished through judicial (Chancery) process, not self-help forfeiture; equity’s anti-penalty rule caps forfeiture	new-jersey	Gallicchio v. Jarzla, 18 N.J. Super. 206, 86 A.2d 820 (App. Div. 1952) — gallicchio-v-jarzla-1952 (equitable conversion / title-as-security); Kutzin v. Pirnie, 124 N.J. 500, 591 A.2d 932 (1991) — kutzin-v-pirnie-1991 (anti-penalty / restitution; deposit-forfeiture posture — no NJ opinion squarely foreclosing a multi-year installment land contract as a mortgage was retrieved, see new-jersey needs_verification)
Treat-as-mortgage; true strict foreclosure SURVIVES but is gated — vendee holds equity of redemption; only foreclosure extinguishes it; strict (no-sale) decree barred absent a finding of no substantial value in excess of the debt — otherwise foreclosure by judicial sale	vermont	12 V.S.A. §§ 4941(c), 4945; Prue v. Royer, 2013 VT 12 — prue-v-royer-2013

How the remedy actually runs

• The statutory “deeming” states (Oklahoma, Florida). The cleanest path: a statute converts the contract for deed into a mortgage by operation of law, so the general mortgage-foreclosure machinery applies wholesale. Oklahoma’s § 11A deems any contract for deed made to secure payment of money a mortgage “subject to the same rules of foreclosure,” and bars foreclosure altogether unless the instrument is recorded and mortgage tax is paid — a recording precondition with real teeth for an unrecorded seller. Florida’s § 697.01 deems any instrument given to secure payment of money a mortgage (subject to a bona-fide-purchaser exception), routing a defaulted agreement for deed into Chapter 702 judicial foreclosure of the buyer’s equity of redemption. Sources: 16 Okla. Stat. § 11A; Fla. Stat. § 697.01.

• The categorical case-law states (Kentucky). No equity threshold at all: Sebastian v. Floyd holds the forfeiture clause unenforceable regardless of how little the buyer has paid, treats the seller as holding “bare legal title, as security,” and limits the seller to a judicial sale. This is the strongest buyer protection short of a statute, because the court need not weigh equity to deny forfeiture. Source: Sebastian v. Floyd, 585 S.W.2d 381, 382–84 (Ky. 1979).

• The substantial-equity-bar states (Indiana, and the Skendzel line generally). Forfeiture is barred once the buyer crosses an equity line; below it, forfeiture (or an abandonment exit) may stand. Skendzel recharacterizes the vendor’s interest as a lien and routes the substantially-paid defaulter into mortgage foreclosure with a right of redemption. Arkansas, New York (Bean v. Walker), California (Petersen v. Hartell), and Hawaii (Jenkins v. Wise) operate on the same equity-keyed logic, each cutting off the buyer’s interest only by a foreclosure/judicial process that returns surplus. Sources: Skendzel v. Marshall, 301 N.E.2d 641 (Ind. 1973); Bean v. Walker, 95 A.D.2d 70 (N.Y. App. Div. 1983); Petersen v. Hartell, 40 Cal.3d 102 (1985).

• The deficiency-and-sale states (Nebraska, Idaho). Treat-as-mortgage cuts both ways: because the contract is a mortgage, the seller may pursue a deficiency where the judicial sale proceeds fall short (Nebraska, Porter v. Smith), and the buyer’s accrued equity is realized through the sale-and-surplus mechanism rather than lost to forfeiture (Idaho, Thomas v. Klein, treating strict forfeiture as a penalty). Sources: Porter v. Smith, 240 Neb. 928, 486 N.W.2d 846 (1992); Thomas v. Klein, 99 Idaho 105, 577 P.2d 1153 (1978).

• True strict foreclosure, gated on no-equity (Vermont). Vermont is the textbook illustration of strict foreclosure proper surviving inside a treat-as-mortgage regime. Prue v. Royer holds the contract for deed an equitable mortgage whose equity of redemption can be extinguished only by foreclosure. The seller may obtain a strict (no-sale) decree — but only if the court finds “no substantial value in the property in excess of the mortgage debt” (12 V.S.A. § 4941(c)); where equity exists, the court orders foreclosure by judicial sale even when the instrument contains no power of sale (§ 4945), with any sale surplus distributed to the owner under the separate distribution statute (§ 4954). The no-equity gate is the doctrine’s reconciliation with the anti-forfeiture principle: a no-sale decree is permissible precisely because there is no equity to forfeit. Sources: 12 V.S.A. §§ 4941(c), 4945; Prue v. Royer, 2013 VT 12.

How this differs from forfeiture and from statutory cancellation

• vs. strict forfeiture (missouri, new-mexico, wyoming): there, a forfeiture clause can self-execute (subject to equitable limits), the seller keeps the property and the payments, and the buyer gets no sale and no surplus. Treat-as-mortgage flips each of those defaults: no self-execution, a court process, surplus returned. See forfeiture-vs-foreclosure.
• vs. statutory cancellation (minnesota § 559.21, iowa ch. 656, north-dakota): there, the seller terminates by serving a statutory notice and honoring a fixed cure window — faster and cheaper than a foreclosure suit, but a cancellation, not a sale. Treat-as-mortgage states have no mailed-notice cancellation; the seller’s only path to extinguish the buyer is a judicial foreclosure, and the buyer’s protection is the equity of redemption (and often a post-sale statutory redemption), not a pre-suit cure period.

Primary sources (retrieved 2026-06-08)

• 16 Okla. Stat. § 11A (Constructive mortgage — Exemptions) — contracts for deed made to secure payment of money “shall to that extent be deemed and held mortgages, and shall be subject to the same rules of foreclosure … as are prescribed in relation to mortgages”; no foreclosure unless recorded and mortgage tax paid. Verified via the official Oklahoma code text (2024). https://law.justia.com/codes/oklahoma/title-16/section-16-11a/
• Fla. Stat. § 697.01 (Instruments deemed mortgages) — “All conveyances, obligations conditioned or defeasible, … or other instruments of writing conveying or selling property … for the purpose or with the intention of securing the payment of money … shall be deemed and held mortgages,” subject to a bona-fide-purchaser exception. Verified via flsenate.gov. https://www.flsenate.gov/Laws/Statutes/2023/697.01
• 12 V.S.A. § 4941 (Vermont — Judgment of foreclosure) — § 4941(c): “No decree foreclosing the right of redemption without sale shall be issued absent a finding by the court that there is no substantial value in the property in excess of the mortgage debt….” Verified via legislature.vermont.gov. https://legislature.vermont.gov/statutes/section/12/172/04941
• 12 V.S.A. § 4945 (Vermont — Foreclosure by judicial sale) — liens and mortgages “may … be foreclosed by a judicial foreclosure sale, even if the mortgage does not contain a sale provision instead of a strict foreclosure” (verified verbatim via legislature.vermont.gov). The disposition of sale surplus to the owner is governed by the separate distribution statute (12 V.S.A. § 4954), not § 4945 itself. https://legislature.vermont.gov/statutes/section/12/172/04945
• Sebastian v. Floyd, 585 S.W.2d 381 (Ky. 1979) — forfeiture clause “not enforceable”; seller holds “bare legal title, as security”; “[t]he seller’s remedy for breach of the contract is to obtain a judicial sale of the property” (at 382–84). Holding verified via Google Scholar. https://scholar.google.com/scholar_case?case=2533604115162136241
• Skendzel v. Marshall, 261 Ind. 226, 301 N.E.2d 641 (Ind. 1973) — vendor’s interest is a lien; substantially-paid buyer must be foreclosed like a mortgagor with a right of redemption rather than forfeited. https://law.justia.com/cases/indiana/supreme-court/1973/773s145-2-0.html
• Porter v. Smith, 240 Neb. 928, 486 N.W.2d 846 (Neb. 1992) — vendor “has the right to foreclose on the executory land contract as if it were a mortgage” and may obtain a deficiency. Holding confirmed via the Nebraska/Justia report. https://law.justia.com/cases/nebraska/supreme-court/1992/685.html
• Thomas v. Klein, 99 Idaho 105, 577 P.2d 1153 (Idaho 1978) — strict forfeiture of a land contract is a penalty; equity requires foreclosure and a judicial sale, with surplus to the buyer. (Cited from the idaho page; CourtListener cluster 1230596.) https://www.courtlistener.com/opinion/1230596/thomas-v-klein/
• Lucas v. Bishop, 1998 OK 16, 956 P.2d 871 (Okla. 1998) — a contract for deed is deemed a mortgage under 16 O.S. § 11A and is subject to the same foreclosure rules; the seller’s remedy is foreclosure of a lien, not forfeiture. (CourtListener cluster 1433792; citation corroborated at Justia.) https://www.courtlistener.com/opinion/1433792/lucas-v-bishop/
• Bean v. Walker, 95 A.D.2d 70, 464 N.Y.S.2d 895 (N.Y. App. Div. 1983) — a defaulting installment-contract vendee holds equitable title / an equity of redemption; the vendor must foreclose mortgage-style (or sue for the price) and may not dispossess or enforce a forfeiture-of-payments clause. Citation verified via Leagle/vLex. https://www.leagle.com/decision/198316595ad2d701159
• Prue v. Royer, 2013 VT 12, 67 A.3d 895 (Vt. 2013) — a contract for deed is an equitable mortgage; “the only means to extinguish [the buyer’s] interest [is] foreclosure.” (CourtListener; cross-confirmed on the vermont page.) https://www.courtlistener.com/opinion/1043646/prue-v-royer-sr-and-department-of-liquor-control/

Meta

• needs_verification:
  • Verbatim full-text of Lucas v. Bishop (1998 OK 16) and Bean v. Walker (95 A.D.2d 70) could not be rendered through a public full-text reader this run (CourtListener/Leagle returned 403); the citations and holdings are confirmed via the in-repo verified case pages lucas-v-bishop-1998 / bean-v-walker-1983 and the official § 11A statutory text. Pull a verbatim pinpoint before quoting.
  • Thomas v. Klein and Porter v. Smith holdings are confirmed via the verified idaho / nebraska pages and a secondary report this run; re-pull the primary opinion text for a verbatim pinpoint.
  • Connecticut retains strict foreclosure as the default mortgage remedy and is a plausible second “true strict foreclosure” datapoint for a contract for deed, but its CFD classification here is hybrid and no Connecticut CFD-specific strict-foreclosure holding was retrieved this run — left off the map pending a retrieved primary source (see connecticut).
  • The Arkansas, Alaska, and Pennsylvania rows rest on the case-law classification in their (verified) arkansas / alaska / pennsylvania state pages; confirm the controlling pinpoint case on each before quoting it on this page.
  • New Jersey reaches treat-as-mortgage by equitable conversion (gallicchio-v-jarzla-1952 — vendee is equitable owner, vendor’s title is security) plus equity’s anti-penalty rule (kutzin-v-pirnie-1991). Kutzin is a deposit-forfeiture / restitution decision (an ordinary purchase contract, not a multi-year installment land contract), so it backstops but does not by itself hold that a CFD is foreclosed as a mortgage; no NJ opinion squarely foreclosing a multi-year installment land contract as a mortgage was retrieved (see new-jersey needs_verification). Pull such an opinion before quoting NJ as a clean mortgage-foreclosure datapoint.
  • Whether each treat-as-mortgage state’s post-sale statutory redemption period applies to a foreclosed contract for deed exactly as to a conventional mortgage (e.g., Kentucky’s 6-month KRS 426.530 window; South Dakota’s ch. 21-50 window) — normalize on each state page.
• open_questions:
  • Does the seller’s deficiency right survive uniformly across the treat-as-mortgage states, or only where the deeming statute / case law expressly permits it (confirmed in Nebraska)? Several states’ anti-deficiency mortgage rules may cap it.
  • In the substantial-equity-bar states, is the line measured by amount paid, amount due, or original price, and does crossing it convert the entire remedy to foreclosure or only bar the forfeiture-of-payments clause? (Compare the equity-threshold discussion in forfeiture-vs-foreclosure.)
• cross_links: forfeiture-vs-foreclosure · equitable-conversion · skendzel-v-marshall-1973 · sebastian-v-floyd-1979 · slone-v-calhoun-2012 · lucas-v-bishop-1998 · bean-v-walker-1983 · petersen-v-hartell-1985 · thomas-v-klein-1978 · porter-v-smith-1992 · prue-v-royer-2013 · jenkins-v-wise-1978 · kutzin-v-pirnie-1991 · gallicchio-v-jarzla-1952 · heikkila-v-carver-1985 · lewis-v-premium-investment-corp-2002 · oklahoma · florida · kentucky · indiana · nebraska · idaho · new-york · california · arkansas · hawaii · alaska · pennsylvania · south-carolina · south-dakota · maine · new-jersey · vermont · minnesota · iowa · north-dakota · missouri · new-mexico · wyoming · connecticut
• changelog:
  • 2026-06-08 — Page created. Defined the two senses of “strict foreclosure” (the foreclose-don’t-forfeit genus vs. the no-sale strict-foreclosure term of art), the statute-vs-case-law routes into treat-as-mortgage, and the no-equity gate on a true strict (no-sale) decree. Built the cross-jurisdiction map for OK, FL, KY, IN, NE, ID, NY, CA, AR, HI, AK, PA, SC, SD, ME, NJ, VT from the verified state pages, confirming the controlling authorities this run by retrieving the primary text of Fla. Stat. § 697.01, 12 V.S.A. §§ 4941/4945, 16 O.S. § 11A, and the Sebastian v. Floyd holding, and corroborating the remaining cases against the in-repo verified case/jurisdiction pages.
  • 2026-06-08 — Adversarial citation-verification pass. Re-retrieved and confirmed Fla. Stat. § 697.01 (verbatim, flsenate.gov), 12 V.S.A. § 4941(c) and § 4945 (verbatim, legislature.vermont.gov), 16 O.S. § 11A (oksenate.gov / OBA), and the holdings of Sebastian v. Floyd, Skendzel v. Marshall, Bean v. Walker, Porter v. Smith, Thomas v. Klein, Lucas v. Bishop, Prue v. Royer, Petersen v. Hartell, Lewis v. Premium Investment, Heikkila v. Carver, and Slone v. Calhoun via >=2 sources each — all real and supporting their rows. Corrected the New Jersey row: authority changed from Kutzin v. Pirnie alone (a deposit-restitution case) to Gallicchio v. Jarzla (equitable conversion / title-as-security) + Kutzin (anti-penalty), with an honest needs_verification flag that no NJ opinion foreclosing a multi-year CFD as a mortgage was retrieved. Corrected § 4945 over-attribution: surplus distribution is governed by § 4954, not § 4945. Confirmed all 17 mapped states classify treat_as_mortgage on their own pages (no contradictions); Connecticut correctly kept off the map (hybrid). All wiki-links resolve.

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Disclaimer. This page is legal information, not legal advice, and may be out of date. Contract-for-deed remedy law is frequently amended and turns on the facts of each default. “Strict foreclosure” is used in two senses, and the availability of a no-sale decree turns on a finding of no equity in the property. Confirm the current statute and that any cited case is still good law before drafting, enforcing, or signing an installment land contract, and consult a licensed attorney in the relevant jurisdiction.