David L. Griffin v. LaSalle Bank, N.A.

Summary

The Court held that the circuit court retained jurisdiction to consider a foreclosure-sale purchaser’s claim for the value of repairs and improvements after the sale and title were vacated. Because the amended vacatur order expressly reserved jurisdiction over that claim, the circuit court could continue addressing it notwithstanding the earlier final foreclosure judgment. The Court therefore quashed the First District’s decision and remanded for further proceedings.