SunTrust Bank and another lienholder claimed excess funds left after Douglas County sold property at a tax sale. The trial court awarded the remaining funds to the other lienholder under earlier Georgia decisions holding that a redeeming creditor could claim priority beyond the amount of the pre-sale lien. While the dispute continued, the Georgia appellate courts overruled that line of authority in DLT List and held that a redeeming creditor does not obtain a priority lien against excess tax-sale funds. The Court of Appeals held that the new rule applied to SunTrust’s case because DLT List corrected a judicial misconstruction rather than announced an unforeseeable new rule, and because the competing lienholder could not show justified reliance after the Supreme Court had accepted review. The court rejected arguments that the funds had become vested or that the dispute was moot because the money had been spent. It reversed the final order and remanded for further proceedings under the controlling decisions.