HILL, Justice.

[¶ 1] Anadarko Land Corporation (Anadarko) appeals a district court decision upholding the validity of a 1911 Laramie County tax assessment against minerals owned by Anadarko's predecessor, as well as the tax sale and tax deed that eventually emanated from the failure to pay those taxes. We affirm.

ISSUE

[¶ 2] Anadarko presents a single issue on appeal:

FACTS

[¶ 3] This case presents a dispute over title to certain mineral interests underlying Section 7, Township 14 North, Range 65 West, 6th P.M., in Laramie County (hereinafter Section 7). Section 7, both its mineral and surface estates, was among lands that the United States, in 1901, granted by patent and deed to Union Pacific Railroad Company (Union Pacific). The present title dispute arises out of a 1911 Laramie County tax assessment against Union Pacific's Section 7 mineral interests and the county's subsequent tax sale and issuance of a tax deed for the property.

A. Tax Assessment and Sale

[¶ 4] In 1911, Laramie County assessed taxes on the unproduced minerals underlying Section 7. Union Pacific did not pay the assessed taxes, and in 1912, Laramie County placed the Section 7 minerals up for bid at a tax sale. No one bid on the Section 7 minerals, so Laramie County bid on and acquired the Section 7 minerals. Union Pacific did not exercise its right to redeem the Section 7 minerals or otherwise seek to recover the property following the 1912 tax sale.

[¶ 5] In 1919, Laramie County sold the Section 7 minerals to Iowa Land & Livestock Company. The tax deed for the Section 7 minerals was not, however, issued until March 1949. The record contains no explanation for the delay in issuing the tax deed, but the parties do not dispute that the deed resulted from the 1912 tax sale and Laramie County's subsequent sale of the Section 7 minerals in 1919.

B. Diverging Chains of Title

[¶ 6] Although Union Pacific did not exercise its right to redeem the Section 7 minerals or otherwise seek to recover the property following the 1912 tax sale, it thereafter conducted itself as if it still owned the Section 7 minerals. In September 1914, Union Pacific conveyed Section 7 to Iowa Land & Livestock Company by warranty deed, and through that deed Union Pacific purported to reserve for itself, its successors and assigns, all oil, coal, and other minerals underlying Section 7. Two claimed chains of title thus emerged following the 1912 tax sale, one stemming from Union Pacific's purported ownership of the Section 7 minerals, and one stemming from Laramie County's tax sale of the minerals and issuance of a tax deed.

1. Appellant Anadarko's Title Claim

[¶ 7] Appellant Anadarko Land Corporation (Anadarko) claims title to the Section 7 minerals by a direct conveyance from Union Pacific, several years after the tax sale. Specifically, in April 1971, Union Pacific conveyed, by quitclaim deed, its rights, title and interest in Section 7 to Union Pacific Land Resources Corporation, Anadarko's predecessor in interest. Effective December 1, 2000, Union Pacific Land Resources Corporation changed its name to RME Land Corporation. Effective October 1, 2002, RME Land Corporation changed its name to Anadarko Land Corporation (Anadarko). Anadarko's claim of title therefore originated with Union Pacific's original 1901 patent and its purported reservation of the Section 7 minerals in the 1914 conveyance from Union Pacific to Iowa Land and Livestock Company, and it concluded with the April 1971 conveyance.1

2. Appellee Family Tree's Title Claim

[¶ 8] Appellee Family Tree Corporation (Family Tree) claims title to portions of the Section 7 minerals. In June 2010, Family Tree obtained certain of the Section 7 mineral interests by entering into an oil and gas lease.2 In June 2014, additional Section 7 mineral interests were conveyed to Family Tree by a mineral grant deed.3 The chain of title that led to Family Tree's lease and the mineral grant deed is as follows:

3. Appellant Three Sisters' Title Claim

[¶ 9] Appellant Three Sisters also claims an ownership interest in the Section 7 minerals and is aligned with Anadarko. In their joint summary judgment memorandum, Anadarko and Three Sisters explained Three Sisters' interest:

[¶ 10] Family Tree hired a landman, Maggie Atkinson, to trace the ownership of their mineral interests. In an affidavit, Ms. Atkinson explained her findings with respect to Three Sisters' claimed interest in the Section 7 minerals:

C. District Court Proceedings

[¶ 11] On June 24, 2014, Family Tree filed in district court a Complaint for Quiet Title and Declaratory Judgment against Anadarko and Three Sisters. Through its complaint, Family Tree alleged that the recorded settlement agreement between Anadarko and Three Sisters was a cloud on its title to its Section 7 mineral interests and it requested that the court declare the settlement agreement null and void and that it quiet title to the property in Family Tree and the owners through whom Family Tree claimed its interest. After answers were filed, the parties eventually filed cross motions for summary judgment.

[¶ 12] The primary dispute between the parties concerned the effect of Laramie County's 1911 tax assessment against Union Pacific's Section 7 minerals and its subsequent tax sale of the property. Anadarko and Three Sisters argued that the tax assessment against Union Pacific's minerals in place was unconstitutional and invalid and the resulting tax deed was therefore void ab initio. Family Tree argued that the tax assessment and tax deed were valid and that the attempt by Anadarko and Three Sisters to challenge the assessment and deed was barred by the six-year statute of limitations.

[¶ 13] On February 11, 2016, the district court issued a decision letter announcing its ruling in favor of Family Tree. The court found that while modern law would not allow taxation of minerals in place, Laramie County's taxing authority was much broader under Wyoming law in 1911. The court thus concluded that the tax was valid and that Union Pacific forfeited its rights to the Section 7 minerals when it failed to redeem or otherwise recover the property within the time allowed by statute. The court also applied the after-acquired doctrine to unify the Section 7 mineral and surface estates, concluding:

[¶ 14] Based on its analysis, the district court concluded that neither Anadarko nor Three Sisters had an interest in the Section 7 minerals and it declared their 2001 Settlement Agreement an invalid cloud on the title. The court thereafter, on March 29, 2016, entered its Order Granting Summary Judgment. On April 28, 2016, Anadarko and Three Sisters filed a timely notice of appeal to this Court.5

STANDARD OF REVIEW

[¶ 15] We review the district court's entry of summary judgment as follows:

Cheyenne Newspapers, Inc. v. City of Cheyenne, 2016 WY 125, ¶ 10, 386 P.3d 329, 333 (Wyo. 2016).

DISCUSSION

[¶ 16] The sole question Anadarko has presented on appeal is whether Laramie County's 1912 tax sale of the Section 7 minerals and the resulting tax deed were void ab initio. The answer to this question is pivotal in resolving this title dispute because a void deed is a nullity, making it ineffective to transfer title and ineffective to set a statute of limitations running. Wayt v. Urbigkit, 2007 WY 34, ¶ 10, 152 P.3d 1057, 1060 (Wyo. 2007) (void title wholly ineffective to pass title); Denny v. Stevens, 52 Wyo. 253, 73 P.2d 308, 310 (1937) (tax deed void on its face will not set statute of limitations in motion). The ineffectiveness of a void deed distinguishes it from a voidable deed:

23 Am.Jur.2d Deeds § 163 (Dec. 2016 update) (footnotes omitted); see also First Interstate Bank of Sheridan v. First Wyo. Bank, N.A., 762 P.2d 379, 383 (Wyo. 1988) (quoting Fallon v. Triangle Mgmt, 169 Cal.App.3d 1103, 215 Cal.Rptr. 748, 750 (1985)) ("Until a voidable deed is declared void, it is fully operative."); Lake Canal Reservoir Co. v. Beethe, 227 P.3d 882 (Colo. 2010) ("A tax deed that is not void may still be voidable, so long as the claim to recover property is brought within the applicable statute of limitations.").

[¶ 17] The Colorado Supreme Court has elaborated on the interplay between a statute of limitations and a void or voidable tax deed:

Lake Canal Reservoir Co., 227 P.3d at 886-87 (quoting Delsas ex rel. Delsas v. Centex Home Equity Co., 186 P.3d 141, 144 (Colo. App. 2008)).

[¶ 18] In light of these principles, the question before us, stated in broad terms, is whether the tax deed is void, meaning it is subject to collateral attack at any time, or voidable, meaning Anadarko's present challenge to its validity is barred by the statute of limitations.6 Our resolution of the title dispute between Anadarko and Family Tree thus depends on whether the alleged defect in Laramie County's 1911 tax assessment rendered the tax deed void. This requires that we answer two narrower questions: A) What types of defects in a tax assessment will render a tax deed void?; and B) Is the alleged defect in Laramie County's 1911 tax of the Section 7 minerals that type of a defect?

A. Rule Governing Whether Tax Assessment Defect will Void Tax Deed

[¶ 19] Anadarko argues that Laramie County's 1911 tax assessment against the Section 7 minerals violated the Wyoming Constitution and that any constitutional defect in a tax assessment mandates a conclusion that the resulting tax sale and deed were void. Family Tree counters that under Wyoming precedent, a tax deed is void only if a defect can be found on the face of the deed. We disagree with both positions.

[¶ 20] In two of our early cases addressing the statute of limitations for challenging a tax deed, this Court held that a tax deed that is void on its face will not set in motion the statute of limitations applicable to the recovery of property sold for taxes. Mathews v. Blake, 16 Wyo. 116, 92 P. 242, 244 (1907); Denny, 73 P.2d at 310. In Denny, the Court cited to Colorado precedent that described a deed that is fair on its face as "one where extraneous evidence is necessary to show the illegality of the conveyance." Id. at 310. It is based on this language that Family Tree argues:

[¶ 21] Essentially, Family Tree contends that since Denny holds that a facial defect in a tax deed will render that deed void, the corollary must also be true, that a tax deed can only be declared void if the alleged defect in the deed appears on the deed's face. We find no support for this corollary rule in either the Denny decision itself or in our decisions subsequent to Denny.

[¶ 22] First, although the Court in Denny did cite to the foregoing language concerning when a deed would be deemed fair on its face, we do not read this as a holding by the Court that necessarily proscribed consideration of extrinsic evidence. To the contrary, the Court went on to say:

Denny, 73 P.2d at 310 (quoting St. Louis Smelting & Refining Co. v. Kemp, 104 U.S. 636, 644, 26 L.Ed. 875 (1881)).

[¶ 23] This language suggests that the Court recognized that a search for a facial defect in a tax deed might very well encompass consideration of information outside the document itself. Perhaps more importantly, however, is the fact that the Court in Denny specifically declined to address the question whether a tax deed could be declared void for a reason other than a facial defect. In particular, it was argued to the Court that the tax deed in question was void for jurisdictional defects and the statute of limitations would not run regardless of whether those defects appeared on the face of the deed or not. Denny, 73 P.2d at 309-10. The Court acknowledged the argument but concluded it was one, among others, that the Court need not and would not address. Id. at 310.

[¶ 24] Based on these considerations, we read Denny to hold no more than that a facial defect in a tax deed is one ground, not the only ground, for finding a tax deed void. Our decisions subsequent to Denny, which addressed defects other than facial defects, verify this reading. See, e.g., Thompson-Green v. Estate of Drobish, 2006 WY 126, ¶ 12, 143 P.3d 897, 901 (Wyo. 2006) (failure of tax purchaser to make diligent effort to serve notice of redemption period on all co-tenants rendered tax deed void); McCarthy v. Union Pac. Ry. Co., 58 Wyo. 308, 131 P.2d 326, 328 (1942) (declaring tax deed void where tax assessment was not made in name of property's true owner).

[¶ 25] We turn then to Anadarko's argument that if a tax assessment violates any state constitutional provision, the resulting tax sale and tax deed must be deemed void. We rejected Family Tree's proposed ground for finding a tax deed void as being too narrow, and we now reject Anadarko's proposed ground as too broad.

[¶ 26] There are jurisdictions that hold that a defective tax assessment will render the resulting tax sale and tax deed void. See, e.g., Weir v. Gillespie, 26 Ohio App.3d 48, 498 N.E.2d 177, 180 (1985) ("A tax purchaser acquires no title, at law or in equity, unless the land has been taxed and a sale conducted according to law."); Dawdy v. Holt, 281 Ark. 171, 662 S.W.2d 818, 819 (1984) ("[I]t has long been the law in Arkansas that when a tax deed to mineral interests derives from a defective assessment, it is void."); Thaxton v. Beard, 157 W.Va. 381, 201 S.E.2d 298 (1973) (tax deed must be supported by valid tax assessment); Lehfeldt v. Adams, 130 Mont. 395, 303 P.2d 934, 936 (1956) (invalid assessment on minerals in place resulted in void tax deed); Kimble v. Allen, 298 P.2d 1042, 1044 (Okla. 1956) (tax deed void where property listed and sold for amount in excess of taxes owing); Cameron Estates v. Deering, 308 N.Y. 24, 123 N.E.2d 621, 623-24 (1954) (double assessment rendered tax deed void). In Cameron Estates, the New York court explained the policy served by its ruling:

Cameron Estates, 123 N.E.2d at 624.

[¶ 27] The policy cited by the New York court is compelling. So too, however, is the policy of promoting the reliability of property records. Our Court has recognized this tension in discussing deed defects that will render a deed voidable as opposed to void.

Harney v. Montgomery, 29 Wyo. 362, 213 P. 378, 383 (1923) (quoting Nat'l Bank of Fredericksburg v. Conway, 1 Hughes 37, 46, 17 F.Cas. 1202); see also Grose v. Sauvageau, 942 P.2d 398, 403 (Wyo. 1997) ("Public policy requires that subsequent purchasers be able to rely on the title shown in public records."); Shaffer, 204 S.E.2d at 411 ("[P]ublic policy is to require every taxpayer to bear his share of the taxes and to obtain certainty in land titles so that the land may be productively used.").

[¶ 28] We are also mindful of the policy objectives underlying any statute of limitations. We have observed:

Robert L. Kroenlein Trust ex rel. Alden v. Kirchhefer, 2015 WY 127, ¶ 24, 357 P.3d 1118, 1126 (Wyo. 2015) (quoting Lieberman v. Mossbrook, 2009 WY 65, ¶ 25, 208 P.3d 1296, 1305 (Wyo. 2009)) (emphasis in original).

[¶ 29] Against the backdrop of these competing policy considerations, we must determine where the line should be drawn between a tax assessment defect that renders a tax deed void and one that renders the deed voidable. In our search for Wyoming cases that define tax assessment defects that will render a tax deed void, we found only one type of defect in the assessment itself that had been addressed: the taxing entity's failure to assess the property tax against the true owner of the property. See Morad v. Brown, 549 P.2d 312, 314 (Wyo. 1976); Tibbals v. Bd. of County Com'rs of Fremont County, 74 Wyo. 232, 286 P.2d 598, 599-600 (1955); McCarthy, 131 P.2d at 328; Hecht v. Boughton, 2 Wyo. 385, 402-03 (1881). In each of these cases, the Court held that a tax assessment issued against someone other than the record owner of the property resulted in a void tax sale and tax deed. Id. The Court in McCarthy explained that the defect was fatal to the deed because of the jurisdictional nature of the requirement that the property be assessed against the record owner. McCarthy, 131 P.2d at 329. The Court further commented in that decision:

McCarthy, 131 P.2d at 333 (quoting Blackwell on Tax Titles 513 (4th ed.)) (emphasis added).

[¶ 30] McCarthy instructs that the type of defect in an assessment that will render the resulting tax sale and tax deed void is a jurisdictional defect. This conclusion is consistent with the approach recently announced by the Colorado Supreme Court in Lake Canal Reservoir Co. v. Beethe, 227 P.3d 882 (Colo. 2010), where that court addressed the validity of a tax deed that was issued following a tax assessment that was alleged to have been made in violation of the Colorado constitution. We find the Colorado court's reasoning persuasive and adopt its approach to evaluating defects alleged in a tax assessment and their effect on the resulting tax deed.

[¶ 31] In Lake Canal Reservoir, the court addressed a title dispute over a tract of land containing a reservoir used for irrigation, farming uses, and recreation. Lake Canal Reservoir, 227 P.3d at 884. Weld County assessed taxes on the property in 1993, and those taxes were not paid. Id. The county then placed a tax lien on the property and eventually sold the property and issued a tax deed, which was recorded in 1997. Id. The petitioners filed a quiet title action in 2003 alleging that the tax deed was void on a number of grounds, including an allegation that the underlying tax assessment violated a Colorado constitutional provision that restricted taxation of reservoirs used for irrigation. Id. The lower court found the tax deed void, but an intermediate appellate court reversed that holding and ruled that the tax deed was voidable, not void, and that petitioners' challenge was therefore barred by the five-year statute of limitations. Id. The Colorado Supreme Court affirmed. Id.

[¶ 32] In addressing whether the tax deed was void or voidable, the Colorado Supreme Court undertook a review of its decisions regarding the validity of tax deeds and announced a rule the court found captured the intent of its prior decisions. Lake Canal Reservoir, 227 P.3d at 887-89. The court held:

Lake Canal Reservoir, 227 P.3d at 889 (emphasis added).

[¶ 33] Using this rule, the Colorado court addressed the alleged defects in the tax deed to the reservoir property.7 The court found that Weld County had likely violated the constitutional limitation on taxation of reservoirs when it taxed the entire reservoir, including the portion used exclusively for irrigation, but it concluded that the defect made the tax deed voidable rather than void. Id. at 891. The court reasoned:

Lake Canal Reservoir, 227 P.3d at 891 (footnote omitted).

[¶ 34] This holding is interesting because the provision of the Colorado constitution that restricts taxation of reservoirs used for irrigation purposes is not equivocal. It states that such properties "shall not be separately taxed."8 Colo. Const. Art. 10, § 3(1)(d); see also Colo. Rev. Stat. Ann. § 39-3-104 (West 2016) ("Ditches, canals, and flumes which are owned and used by any person exclusively for irrigating land owned by such person shall be exempt from the levy and collection of property tax."). Yet the Colorado court was able to draw what we can only describe as a very fine line, ruling that the defect in the assessment against the exempt portion of the reservoir was a defect in the scope of the tax, not an assessment outside the county's taxing authority.

[¶ 35] We view the fine line drawn by Colorado court in Lake Canal Reservoir as a reflection of the court's reluctance to disturb settled property records without the clearest of showings that the taxing entity exceeded its taxing authority. We liken it to our reluctance to allow collateral jurisdictional attacks on judgments after the time for a direct appeal or challenge has passed. In such situations, we must consider the need for "a disciplined observance of jurisdictional limits coupled with the need for finality of judgments." Matter of Guardianship of MKH, 2016 WY 103, ¶ 25, 382 P.3d 1096, 1102 (Wyo. 2016) (quoting Linch v. Linch, 2015 WY 141, ¶ 18, 361 P.3d 308, 314 (Wyo. 2015)). To balance these competing considerations, we have held that we will set aside a final judgment as void for lack of jurisdiction in only:

Matter of Guardianship of MKH, ¶ 29, 382 P.3d at 1103 (quoting Linch, ¶ 19, 361 P.3d at 314).

[¶ 36] Because we share the Colorado Supreme Court's reluctance to set aside settled property records, we adopt a variation on that court's announced ruling. We agree with the Colorado court that:

Lake Canal Reservoir, 227 P.3d at 889.

[¶ 37] We add to this a caveat. When the alleged defect is one in the tax assessment itself, we will find a lack of authority or jurisdiction on the part of the taxing entity only if there was a total want of jurisdiction, meaning there was no arguable basis for jurisdiction and the tax assessment was a clear usurpation of power.

[¶ 38] Having determined where we will draw the line between a tax assessment defect that will render a tax deed void and one that will render the tax deed voidable, we turn to our review of Laramie County's tax assessment against the Section 7 minerals.

B. Application of Rule Governing Tax Assessment Defects

[¶ 39] Anadarko argues that Article 15, § 3 of the Wyoming Constitution prohibits the taxation of minerals in place and that Laramie County's 1911 tax assessment violated that constitutional bar, resulting in a void tax deed. We have little difficulty accepting the proposition that the 1911 tax assessment against the Section 7 minerals was erroneous. We do not, however, find this to be a jurisdictional error and we therefore reject the argument that the error rendered the tax deed void.

[¶ 40] Article 15, § 3 provides:

Wyo. Const. art 15, § 3 (LexisNexis 2015).

[¶ 41] This provision does not exempt minerals or mines from taxation. It is directed to the manner in which minerals will be taxed. In contrast, art. 15, § 12, which does exempt specific properties from taxation, provides:

Wyo. Const. art. 15, § 12 (LexisNexis 2015) (emphasis added).

[¶ 42] Importantly, article 15, § 12 authorizes the legislature to exempt other property of its choosing from taxation. In 1910, this resulted in the following statutory framework governing the county's taxing authority:

Wyo. Comp. Stat. (1910).

[¶ 43] Under the 1910 statutes, which governed Laramie County's taxing authority in 1911, minerals were not exempted from taxation and the county clearly had authority to tax minerals. Wyo. Stat. Comp. § 2324 (1910) ("All other property, real and personal, within this state is subject to taxation in the manner herein directed[.]").9 We presume, however, that had Union Pacific timely challenged the 1911 tax assessment, there is a fair likelihood it would have succeeded in having the tax set aside. See Milliron Oil Co. v. Connaghan, 76 Wyo. 330, 302 P.2d 256, 259 (1956) (interpreting statutory provision materially similar to Wyo. Comp. Stat. § 2449 (1910) and holding that no valid assessment could be made against minerals until produced). The error in the 1911 assessment was not, however, a clear jurisdictional error. It was an error in the manner of taxation — in the when and how of the assessment.

[¶ 44] Finding no clear usurpation of the county's taxing power, we conclude that the error in Laramie County's tax assessment against the Section 7 minerals rendered the resulting tax deed voidable not void. Anadarko's challenge to the validity of the tax deed is therefore barred by the six-year statute of limitations. See Wyo. Stat. Ann. § 39-13-108(e)(vii)(D) (LexisNexis 2015) (previously codified at Wyo. Comp. Stat. § 2395 (1910)).

C. After-Acquired Title Doctrine

[¶ 45] Anadarko did not state an issue for our review with respect to the district court's application of the after-acquired title doctrine. Anadarko does contend, however, that the court erred in applying the doctrine because the doctrine has no application to a void deed. Because we have determined the tax deed was not void, we also reject this argument. Anadarko's remaining argument with respect to the doctrine's application is that the district court erred in applying the doctrine because Anadarko's predecessor in interest had no intention to perfect title. Other than citing cases, Anadarko provides no analysis or argument on this question, and we therefore do not review any further the district court's application of the after-acquired title doctrine. See Golden v. Guion, 2016 WY 54, ¶ 31, 375 P.3d 719, 727, n.5 (Wyo. 2016) (Court does not consider issues not supported by cogent argument).

CONCLUSION

[¶ 46] We hold that the line between a void and a voidable tax deed does not depend on the nature of the evidence used to determine the deed's defect, but rather on the nature of the defect itself. A deed is void — and therefore not subject to the statute of limitations — when the taxing entity lacked the authority or jurisdiction to issue it. When the alleged defect is one in the tax assessment itself, we will find a lack of authority or jurisdiction on the part of the taxing entity only if there was a total want of jurisdiction, meaning there was no arguable basis for jurisdiction and the tax assessment was a clear usurpation of power.

[¶ 47] The error in Laramie County's 1911 tax assessment against the Section 7 minerals was not a clear jurisdictional error, and finding no clear usurpation of the county's taxing power, we conclude that the error rendered the resulting tax deed voidable not void. Because the validity of the tax deed was not challenged within the time allowed by the six-year statute of limitations, the tax deed has been and remains fully operative.

[¶ 48] Affirmed.

HILL, Justice, delivered the opinion of the Court;

FOX, Justice, filed a dissenting opinion.

FOX, Justice, dissenting.

[¶ 49] I respectfully dissent. I concur with the majority's analysis of what makes a deed void rather than voidable, but I conclude that the application of the law to the tax deed at issue must result in finding the deed is void.

[¶ 50] There is no dispute that Article 15, § 3 of the Wyoming Constitution prohibits the taxation of minerals in place; and it meant the same thing in 1911, even though it may have been misunderstood at that time. To the extent there were statutes in 1911 which may have authorized taxation of minerals in place, they were unconstitutional. (See, e.g., Billis v. State, 800 P.2d 401, 450 (Wyo. 1990) ("The legislature may not enact a statute which is in conflict with a provision of the state Constitution.") (internal citations omitted)). The 1911 tax assessment was not an error in the "when and how;" it was a complete failure of authority to tax. The tax at issue here resembles the cases discussed by the majority in which tax deeds were found to be void because of the taxing entities' failure to assess the property tax against the true owner of the property. Morad v. Brown, 549 P.2d 312, 314 (Wyo. 1976); Tibbals v. Bd. of Cty. Comm'rs of Fremont Cty., 74 Wyo. 232, 286 P.2d 598, 599-600 (1955); McCarthy v. Union Pac. Ry. Co., 58 Wyo. 308, 131 P.2d 326, 328 (1942); Hecht v. Boughton, 2 Wyo. 385, 402-03 (1881). Here, Laramie County did not act "within the pale of [its] authority," McCarthy, 131 P.2d at 333, and the tax deed is void. See Dufur v. Nampa & Meridian Irrigation Dist., 128 Idaho 319, 912 P.2d 687, 693 (Idaho Ct. App. 1996) ("Because the noted statutes were found to be unconstitutional, the tax deeds were appropriately voided and title was restored to the Dufurs."). Lake Canal Reservoir Co. v. Beethe, 227 P.3d 882 (Colo. 2010), likewise fails to support the majority's conclusion. There, the court found that although the tax on the reservoir "may have been excessive, at least some of that assessment was authorized." Id. at 891. Here, the county completely lacked authority to tax minerals in place. There was no arguable basis for jurisdiction and the tax assessment was a clear usurpation of power.

[¶ 51] While I appreciate the value of finality in real estate transactions, that may be a matter best left to the legislature. In fact, the legislature has taken action to impose a statute of limitations on void tax deeds, Wyo. Stat. Ann. § 34-2-132 (LexisNexis 2015), and it expressly omitted mineral tax deeds from those provisions. Wyo. Stat. Ann. § 34-2-135 (LexisNexis 2015). "The legislature is presumed to act in a thoughtful and rational manner with full knowledge of existing law." Barlow Ranch, Ltd. P'ship v. Greencore Pipeline Co. LLC, 2013 WY 34, ¶ 57, 301 P.3d 75, 94 (Wyo. 2013). If it had wanted to impose a statute of limitations on void tax deeds, it would have here.

[¶ 52] For these reasons, I would find that the tax deed at issue is void.