Deutsche Bank National Trust v. Peters

Court entered a judgment for foreclosure and sale on Defendant’s property. Following a judicial sale at which Plaintiff purchased the property, Plaintiff moved for an order confirming the sale. Defendant objected, arguing that language in the notice of sale requiring people entering the foreclosure sale room to bring a photo ID violated the Illinois Human Rights Act (“HRA”). Specifically, Defendant argued that the notice discriminated on the basis of national origin since people who entered the country without proper documentation would be unable to participate in the sale. Court entered order approving the sale finding, in part, that Defendant lacked standing to raise the HRA issue. Court properly found that Defendant lacked standing. Defendant did not identify a person, including himself, who went to the judicial sale with the adequate funds to purchase the property from the bank, but was denied access, and thus did not identify a distinct and palpable injury traceable to the notice of sale.