American Advisors Group v. Cockrell

Plaintiff, which had a reverse mortgage as to long-time homeowners, filed foreclosure action, and court entered default judgment of foreclosure and sale; Plaintiff was then the successful bidder at foreclosure sale, and deed to property was executed in favor of Plaintiff. Court denied homeowners' Section 2-1401 petition for relief from judgment. As there was no extrinsic fraud that deprived the circuit court from acquiring valid jurisdiction, foreclosure judgment was not void ab initio, as section 15-1509(c) of Foreclosure Law bars homeowners' claims. The vesting of title by deed pursuant to section 15-1509(b) is an entire bar of all claims of parties to the foreclosure. (CUNNINGHAM and CONNORS, concurring.)