JP Morgan Chase Bank, NA v. Winthrop Properties, LLC

Summary

The court held that the statutory bar on further action after mortgage foreclosure does not prevent a lender from recovering the unpaid debt from guarantors whose liability arises under a separate guarantee. Because the guarantors were not parties to the foreclosure claim and had no interest or right of redemption in the mortgaged property, the lender was not required to pursue a timely deficiency judgment against them. The court reversed the Appellate Court and directed it to affirm the trial court's damages judgment.