JP Morgan Chase Bank, N.A. v. Mendez, 320 Conn. 1

Defendant Mendez executed a promissory note for $296,000 secured by a mortgage on 45 Derek Lane, Windsor.
Plaintiff JP Morgan Chase Bank, N.A. acquired the note and mortgage; default was declared in 2012.
Trial court entered default against Mendez on September 19, 2013, and ordered a judgment of foreclosure by sale for September 30, 2013.
A public foreclosure sale occurred January 11, 2014; plaintiff was the sole bidder and winner.
Mendez first appeared January 14, 2014 and moved to open and vacate the judgment of foreclosure by sale under § 49-15.
Trial court denied the motion, concluding § 52-212 governs, § 49-15 applies to strict foreclosures, and equity did not justify opening the judgment; appellate court transferred and held moot, dismissing the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is moot and justiciable	Mendez argues to reach §52-212 vs §49-15 issues.	Appellate review should proceed since equity could provide relief.	Appeal dismissed as moot; no practical relief available.
Proper statutory basis for opening a foreclosure by sale judgment	§52-212 governs opening of judgments; §49-15 is inapplicable to sale judgments.	§49-15 applies to opening judgments, including foreclosure by sale.	Moot; court did not reach merits, but reflects §52-212 applicability per court's moot ruling.

Wyatt Energy, Inc. v. Motiva Enterprises, LLC, 308 Conn. 719 (2013) (mootness and unreviewable issues; practical relief required)
Gagne v. Vaccaro, 311 Conn. 649 (2014) (recusal issue moot due to unchallenged ruling)
Valvo v. Freedom of Information Comm'n, 294 Conn. 534 (2010) (threshold mootness and justiciability doctrine)
Moraski v. Connecticut Board of Examiners of Embalmers & Funeral Directors, 291 Conn. 242 (2009) (mootness and practical relief considerations)