## Facts

- Thomas W. Conroy, an active-duty U.S. Army officer, owned real property in Danforth, Maine.
- Conroy failed to pay local real estate taxes, and the town acquired the property through the tax-sale process and later sold it to subsequent purchasers, including Aniskoff.
- Conroy sued the town and the purchasers, arguing that § 525 of the Soldiers’ and Sailors’ Civil Relief Act of 1940 suspended (tolled) Maine’s statutory redemption period for tax-sold property during his military service.
- Conroy contended that, because the redemption period was tolled, the town could not have obtained good title before selling the property.

## Issues

1. Whether SSCRA § 525 tolls a state-law redemption period for real property during a service member’s active military service without requiring proof that military service prejudiced the ability to redeem.

## Decision

- The Supreme Court reversed the judgment of the Maine Supreme Judicial Court and remanded.
- The Court held that § 525’s tolling applies automatically during the period of military service.
- The Court rejected any requirement that a service member show prejudice, hardship, or actual impediment caused by military service to obtain tolling.
- Justice Scalia concurred in the judgment, agreeing the text controlled but disputing reliance on legislative history where statutory language is clear.

## Legal Principles

- When § 525 states that the period of military service “shall not be included” in computing any redemption period for property sold or forfeited for taxes or assessments, courts must apply that directive as written.
- SSCRA § 525 contains no implicit prejudice or hardship condition; importing such a requirement conflicts with the statute’s text and structure.
- Where Congress includes express prejudice requirements in other provisions of a comprehensive statute, courts should not add a prejudice requirement to a provision that omits it.

## Conclusion

The Court held that SSCRA § 525 suspends state redemption periods for real property during active military service as a matter of law, and a service member need not prove that military service impaired the ability to redeem.


Conroy v. Aniskoff, 507 U.S. 511 (1993)