PRECEDENTIAL

     UNITED STATES COURT OF APPEALS
          FOR THE THIRD CIRCUIT

                ________________

                   No. 18-1650
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   IN RE: FRANK J. HACKLER AND DAWN A.
             STELZLE-HACKLER,

                                 Debtors

FRANK J. HACKLER; DAWN A. STELZLE-HACKLER

                         v.

     ARIANNA HOLDINGS COMPANY, LLC,

                                           Appellant
                                  _

   On Appeal from the United States District Court
            for the District of New Jersey
      (D. C. Civil Action No. 3-17-cv-06589)
    District Judge: Honorable Peter G. Sheridan
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             Argued on March 12, 2019

 Before: MCKEE, PORTER and ROTH, Circuit Judges
            (Opinion filed: September 12, 2019)


Elliott J. Almanza       (ARGUED)
Keith A. Bonchi
Goldenberg, Mackler, Sayegh, Mintz, Pfeffer, Bonchi & Gill
660 New Road
Suite 1-A
Northfield, NJ 08225

             Counsel for Appellant

Leonard C. Walczyk        (ARGUED)
Wasserman, Jurista & Stolz
110 Allen Road
Suite 304
Basking Ridge, NJ 07920

             Counsel for Appellee

Tara A. Twomey
National Association of Consumers Bankruptcy
1501 The Alameda
Suite 200
San Jose, CA 95126

             Counsel for Amicus Appellee


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                        OPINION
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                             2
ROTH, Circuit Judge

       This case requires us to decide, as a matter of first
impression, whether a transfer of real estate title conducted
via New Jersey’s tax foreclosure procedures may be voided as
“preferential” under § 547(b) of the United States Bankruptcy
Code. 1 Appellant Arianna Holding Company LLC purchased
a tax lien on a piece of property owned by Frank J. Hackler
and Dawn Stelzle-Hackler. Arianna eventually obtained title
to the Hacklers’ property via foreclosure proceedings.
Shortly after Arianna obtained title, the Hacklers filed for
bankruptcy and sought to void the transfer of the title as
preferential. The Bankruptcy Court and the District Court
ruled in favor of the Hacklers and voided the title transfer.
Because the title transfer undisputedly meets § 547(b)’s
requirements for avoidance and because the federalism
concerns raised by Arianna cannot overcome the plain
language of the Bankruptcy Code, we will affirm.

                                 I

       The Hacklers failed to pay property tax on a parcel in
North Brunswick, New Jersey. On June 25, 2013, the
township held a duly advertised tax sale—a public auction for
the unpaid municipal lien on the property. While mortgage
foreclosures involve bidding on the actual property, at New
Jersey tax foreclosures the public bids only on the rate of
interest on the unpaid taxes; the lowest bidder wins. 2
Accordingly, the redemption amount for a tax lien

1
    

(b).
2
    N.J.S.A. 54:5-32.




                             3
certificate—the amount the property owner must pay to
recover the lien and prevent foreclosure—is calculated from
the accrued taxes plus interest, not from the value of the
underlying property. 3 At the tax sale for the lien on the
Hacklers’ property, Phoenix Funding, Inc., bid the interest
rate on the tax sale certificate down to 0% and paid a
premium of $13,500 above the value of the lien. Phoenix
paid the delinquent taxes as they became due and charged the
state-allowed interest rate of 18% on the subsequent taxes. 4

        In New Jersey, tax sale foreclosures are “strict
foreclosures.” 5 If the property owner does not redeem the
certificate by paying the lienholder the redemption amount
(the original unpaid taxes and subsequent taxes plus 18%),
the certificate holder may, after two years, file for a
foreclosure judgment; that judgment vests title directly in the
tax lien certificate holder. After waiting the required two-
yea