Deutsche Bank National Trust v. Puma, 65 N.E.3d 899

Deutsche Bank filed a foreclosure complaint in July 2012 against David and Luz Puma, alleging default on a mortgage and attaching the note, mortgage, and assignment.
Complaint prayed for foreclosure and sale, attorney fees, costs, and specifically requested an order granting possession.
The Pumas answered pro se denying liability; Deutsche Bank moved for summary judgment and a judgment of foreclosure and sale.
Court granted summary judgment and entered a judgment of foreclosure and sale on June 3, 2014, preserving mortgagor possession until sale confirmation.
Property sold to Deutsche Bank; after post-sale motions (including the Pumas’ untimely motion to reconsider), the court confirmed the sale on November 10, 2015, and ordered possession to the purchaser.
The Pumas appealed, arguing the complaint failed to name them as defendants whose possessory rights were sought to be terminated under the Foreclosure Law form (735 ILCS 5/15-1504(a)(3)(T)).

Issue	Plaintiff's Argument (Deutsche Bank)	Defendant's Argument (Pumas)	Held
Whether Deutsche Bank’s complaint validly sought post-confirmation possession over the Pumas despite not using the precise §15-1504(a)(3)(T) language	Substantial compliance with the foreclosure-form pleading and attachments (mortgage, note, assignment) sufficiently identified the Pumas as mortgagors/owners and requested possession	Omission of the precise §15-1504(a)(3)(T) language means the Pumas were not "named" for termination of possessory rights; possession could only be obtained by separate §15-1701 petition or detainer action	Court held substantial compliance sufficed; Pumas were effectively named elsewhere and the possession order on confirmation was proper

(Opinion did not cite authorities with official reporter citations suitable for this list.)