U.S. Bank National Ass'n v. Cook

2024 IL App (3d) 240041-U
CourtAppellate Court of Illinois
DecidedDecember 13, 2024
Docket3-24-0041
StatusUnpublished

This text of 2024 IL App (3d) 240041-U (U.S. Bank National Ass'n v. Cook) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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U.S. Bank National Ass'n v. Cook, 2024 IL App (3d) 240041-U (Ill. Ct. App. 2024).

Opinion

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

2024 IL App (3d) 240041-U

Order filed December 13, 2024 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

U.S. BANK TRUST NATIONAL ) Appeal from the Circuit Court ASSOCIATION, not in its Individual Capacity ) of the 12th Judicial Circuit, but solely as Delaware Trustee, and U.S. BANK ) Will County, Illinois, NATIONAL ASSOCIATION, not in its ) Individual Capacity but solely as Co-Trustee for ) Government Loan Securitization Trust ) 2011-FV1, ) ) Plaintiff-Appellee, ) ) Appeal No. 3-24-0041 v. ) Circuit No. 13-CH-2883 ) ROSEMARY COOK, CYNTHIA LOGAN, ) a/k/a CYNTHIA D. LOGAN, DELSHAWN E. ) LOGAN, CATALYST INTERVENTIONS, ) LLC, UNKNOWN OWNERS AND ) NONRECORD CLAIMANTS, ) ) Defendants ) Honorable ) Theodore Jarz (Cynthia D. Logan, Defendant-Appellant). ) Judge, Presiding.

____________________________________________________________________________

JUSTICE DAVENPORT delivered the judgment of the court. Justices Brennan and Peterson concurred in the judgment. ____________________________________________________________________________

ORDER ¶1 Held: (1) Section 2-1401 ruling is beyond the court’s jurisdiction due to untimeliness. (2) Rule 305(k), which protects third-party purchasers’ rights, is constitutional. (3) Appellant’s failure to secure a stay under Rule 305(k) moots any issue that may adversely affect the third-party purchaser’s interest in the foreclosed property. (4) Postjudgment interest did not accrue while the mortgagee’s voluntary dismissal order—later vacated—rendered the foreclosure judgment inoperative. Dismissed in part; cause remanded for a recalculation of the personal deficiency judgment.

¶2 The circuit court granted a foreclosure judgment in favor of plaintiff, U.S. Bank National

Association (U.S. Bank), and the foreclosed property was sold at auction. U.S. Bank moved for an

order approving the sale, an eviction order, and a $156,360.24 personal deficiency judgment

against defendant Cynthia Logan. The circuit court granted U.S. Bank’s motions in full. On appeal,

Logan argues U.S. Bank engaged in inequitable conduct throughout the case, warranting the

vacatur of all orders entered in its favor. Alternatively, she urges this court to reduce the “highly

inflated” personal deficiency judgment, arguing it includes interest during a period in which

interest could not accrue. For the reasons that follow, we dismiss the appeal in part and remand for

a recalculation of the deficiency judgment.

¶3 I. BACKGROUND

¶4 In December 1998, Logan and a co-borrower executed a mortgage contract secured by

residential property in Bolingbrook. In September 2013, U.S. Bank filed a complaint against

Logan, her co-borrower, and others, seeking to foreclose on the property. The complaint alleged

Logan defaulted on her mortgage payments and owed $197,243.98 in unpaid principal and interest

at a rate of $29 per diem. Logan filed an affirmative defense and a multi-count counterclaim. U.S.

Bank moved to dismiss the counterclaim and to summarily dispose of the affirmative defense. The

court largely granted U.S. Bank’s motion, striking the affirmative defense and allowing only one

of the counterclaim’s counts to proceed. In October 2017, U.S. Bank moved for summary

judgment, order of default, and judgment of foreclosure and sale.

2 ¶5 On January 30, 2018, the circuit court granted U.S. Bank’s motions, entering summary

judgment in favor of U.S. Bank, an order of default against Logan, and a foreclosure judgment

listing a $288,658.36 debt. In April 2018, Logan moved to stay the foreclosure sale, which the

court granted. The court also entered a finding under Illinois Supreme Court Rule 304(a) (eff. Mar.

8, 2016) that no just reason exists to delay enforcement or appeal. In May 2018, Logan appealed

the January 30, 2018, judgments.

¶6 In June 2018, the subject property was sold at auction, and U.S. Bank moved for an order

approving the sale. The court found the bank’s motion moot because of Logan’s timely appeal.

Accordingly, it vacated the judicial sale and ordered the return of the sale funds.

¶7 On March 27, 2019, while the case was pending in the appellate court, U.S. Bank filed a

motion to vacate the January 30, 2018, foreclosure judgment and to dismiss the action, saying it

“voluntarily elects to halt foreclosure proceedings.” U.S. Bank did not notify Logan or the

appellate court of this motion.

¶8 In April 2019, this court filed a Rule 23 order affirming the January 30, 2018, order in its

entirety. See US Bank Trust National Ass’n v. Cook, 2019 IL App (3d) 180324-U. Our mandate

issued in October 2019.

¶9 On December 3, 2019, the circuit court granted U.S. Bank’s motion for voluntary

dismissal, vacating the January 30, 2018, foreclosure judgment.

¶ 10 In March 2020, U.S. Bank moved to vacate the voluntary dismissal order under section 2-

1301 of the Code of Civil Procedure (Code) (735 ILCS 5/2-1301 (West 2020)). The motion stated,

“[O]n March 9, 2020, [U.S. Bank] advised counsel to proceed with the foreclosure as it fully

intends to proceed with its Complaint to Foreclose Mortgage.” The court denied the motion,

3 finding it had lost jurisdiction 30 days after the entry of the dismissal order. 1 U.S. Bank then filed

a section 2-1401 petition to vacate the dismissal order. Id. § 2-1401. It argued counsel had filed

the motion for voluntary dismissal inadvertently and without authorization. U.S. Bank noted

counsel never scheduled the motion for presentment, and the motion “appears to have been granted

off-call.”

¶ 11 On May 17, 2022, the court granted the section 2-1401 petition, thereby reinstating the

January 2018 foreclosure judgment. In September 2022, the court denied Logan’s motion for

reconsideration.

¶ 12 On April 13, 2023, GJR Investments, LLC, purchased the subject property at auction for

$269,000. In October 2023, the court entered an order approving the sale, an eviction order, and a

personal deficiency judgment against Logan for $156,360.24. The deficiency judgment included

postjudgment interest calculated from January 20, 2018, to April 13, 2023, in the amount of

$135,170.82. Logan moved to vacate the order approving the sale, and the court denied her motion.

¶ 13 In January 2024, Logan filed her notice of appeal, requesting the reversal of several circuit

court orders, including the eviction order, grant of the section 2-1401 petition, approval of the

foreclosure sale, and personal deficiency judgment. U.S. Bank moved to dismiss Logan’s appeal

as moot under Illinois Supreme Court Rule 305(k) (eff. July 1, 2017). We ordered the motion taken

with the case.

¶ 14 II. ANALYSIS

¶ 15 Citing the doctrine of unclean hands, Logan’s primary contention on appeal centers on U.S.

Bank’s “course of inequitable conduct” throughout the litigation. This conduct, she argues,

1 The court denied the motion in September 2021, after several pandemic-related continuances.

4 warrants reversing every order entered in favor of U.S. Bank and against Logan. Alternatively, she

argues the circuit court erred in calculating the personal deficiency judgment. As detailed below,

we have jurisdiction to review only one of the orders challenged by Logan—the personal

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2024 IL App (3d) 240041-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/us-bank-national-assn-v-cook-illappct-2024.