Citibank, N. A. v. Data Lease Financial Corporation

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that issues relating to merits of foreclosure judgment could not be appealed after confirmation of sale because earlier order had been final
• holding that “an order in a foreclosure proceeding that directs the immediate sale of specified property is in all respects a final order for purposes of appeal.”
• holding where creditor failed to appeal from an order of judicial sale but waited for the confirmation order, appellate review is limited to the confirmation order itself and jurisdiction to order the sale
• explaining that an order that directs the immediate sale of specified property is final, whereas an order that determines a party’s right to a judicial sale, but does not determine the amount of the debt or actually order the sale, is not
• failure to appeal foreclosure order bars ability to challenge merits of that order in appeal of later order confirming sale
• “[A]n order in a foreclosure proceeding that directs the immediate sale of specified property is in all respects a final order for purposes of appeal.”

Source: CourtListener parenthetical corpus (CC0).