Klauk v. American Samoa Government
1989Held that tax laws permitting the seizure and sale of property must be strictly construed and that the government violates due process if it seizes property without following mandated procedures.
AS
American Samoa
Tax Deed
American Samoa does not conduct tax deed auctions for real property. The territory’s land ownership is largely governed by traditional communal tenure systems, which restrict land alienation to native Samoans. Consequently, there is no statutory mechanism for the government to seize and auction private real estate to satisfy delinquent property tax obligations.
| Upcoming auctions | 0 |
| Counties covered | 5 |
| Scored properties | 0 |
| Last updated | Apr 15, 2026 |
Quick facts
- Sale type
- None
- Redemption period
- N/A
- Sale frequency
- N/A
- Minimum bid
- N/A
- Deed type
- N/A
- Bidder deposit
- N/A
Statutory framework
| Sale Type | Tax Deed |
| Redemption Period | Not applicable. There is no tax deed auction system in American Samoa. |
| Penalty / Interest | Not applicable. |
| Jurisdiction Type | Municipality |
| Jurisdiction Count | 1 |
| Typical Sale Month | Not applicable |
| Assessor Portal | — |
| GIS Portal | — |
| Tax Portal | — |
Sale mechanics
Not applicable. There is no tax deed auction process in American Samoa.
Post-sale obligations
Not applicable.
Quiet title cost estimator
Estimate attorney and court costs for clearing title after a American Samoa tax deed purchase.
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How to bid at a American Samoa tax deed auction
Step-by-step process for participating in American Samoa tax deed sales.
- 1
Not applicable
There is no tax deed auction process in American Samoa.
Applicable statutes
Primary statute sections governing tax deed sales in American Samoa.
A.S.C.A. § 11.0401 et seq.
Governs the collection of income and related taxes, incorporating by reference parts of the U.S. Internal Revenue Code.
A.S.C.A. § 37.0201 et seq.
Governs the alienation of land and the restrictions on transferring land ownership in American Samoa.
Notable case law
Landmark court decisions affecting American Samoa tax deed investors.
American Samoa Government v. Bird
1900Clarified that certain tax statutes do not apply to leased houses on communal land, highlighting the distinction between Western property concepts and Samoan customary land tenure.
Frequently asked questions
Common questions from American Samoa tax deed investors.
- No. There is no statutory framework for the government to conduct tax deed auctions for real property.
- Property taxes are limited and generally not enforced through tax deed sales. The American Samoa Government Tax Office manages tax compliance, but land ownership is primarily governed by customary law.
- No. There are no tax sales, and land alienation is strictly restricted to native Samoans under territorial law.
- The Land and Titles Court adjudicates disputes regarding land ownership and ensures that land transactions comply with both territorial law and traditional customary norms.
- While the government has general authority to collect taxes, the enforcement mechanisms for real property are not structured as tax deed auctions.
- Inquiries should be directed to the American Samoa Government Tax Office in Pago Pago.
Does American Samoa have tax deed auctions?
How are property taxes collected in American Samoa?
Can a non-native buy land at a tax sale in American Samoa?
What is the role of the Land and Titles Court?
Are there property tax liens in American Samoa?
Where can I find information on property tax obligations?
Title Risk Flags
The primary risk in American Samoa is the complex nature of land title. A significant portion of land is held under customary/communal tenure, which is not subject to standard Western fee-simple transfer. Any transaction involving land must comply with strict territorial laws regarding alienation and often requires approval from the Land and Titles Court.
Data sourced from public state statutes, county recorder offices, and AuctionSift's proprietary county monitoring network. Updated weekly.