LaSalle Bank National Association v. Cypress Creek 1 

Bank, which had made $8 million loan, foreclosed on senior apartments construction project. Mortgage predated mechanics liens, the foreclosure sale proceeds were insufficient to satisfy all claims, and the mortgagee had paid for several improvements to property through construction loan disbursements under Section 16 of Mechanics Lien Act. In a proportionality determination under Section 16, the value of the property attributable to improvements paid for with proceeds of a mortgage and construction loan should be attributed toward satisfaction of the mortgage. (KILBRIDE, THOMAS, KARMEIER, and THEIS, concurring.)