KeyBank National Association v. Elizabeth Keniston

Summary

The Maine Supreme Judicial Court vacated the district court’s dismissal and held that a deceased debtor’s estate need not be joined as a party in an in‑rem foreclosure that does not seek a deficiency judgment. The court overruled its prior reading of Alley to the extent it required a debtor or estate in every foreclosure, emphasizing the statutory and title‑theory basis for in‑rem actions. The case was remanded for further proceedings consistent with this opinion.