Illinois Appellate Court
Civil Court
Mortgage Foreclosure
Analyzing case under Wyoming law, Wyoming follows "lien theory" mortgage foreclosure scheme. Mortgages state that secured debt is same debt as company's debt to other company, in unpaid rent for leased equipment. Under Wyoming law, effect of a successful credit bid is to satisfy and discharge a mortgage. Based on plain meaning in mortgage agreements, $22 million credit bid by company satisfied other company's unpaid rent debt to company making credit bid. (CONNORS and HOFFMAN, concurring.)