Leeco, Inc. v. Cornerstone Bank, 898 N.W.2d 653

Cornerstone Bank held a mortgage on Pelican Lake property granted by Leeco, Inc. to secure a guaranty of a $1.2M line of credit to Jacob North Printing.
The lakeshore property consists of three platted lots but four tax parcels (no physical division; a cabin straddles a parcel line); three tax parcels are too small to be buildable individually under zoning.
The mortgage expressly secured the revolving line of credit and "all obligations, debts and liabilities" of grantor or borrower, and permitted sale "all or any part of the Property together or separately."
After Jacob North filed bankruptcy and Leeco defaulted, Cornerstone initiated a foreclosure by advertisement and published a notice stating an amount due of $4,178,993.94; Cornerstone purchased the property at sale for $1,007,437.85.
Leeco later disclosed $4.8M in liabilities to Cornerstone in bankruptcy. Leeco sued to void the sale, claiming (1) the property should have been sold as separate tracts under Minn. Stat. §580.08, and (2) the sale notice misstated the amount due under Minn. Stat. §580.04. The district court granted summary judgment for Cornerstone; Leeco appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the mortgaged premises consist of "separate and distinct tracts" under Minn. Stat. §580.08	Leeco: property is multiple lots/tax parcels and thus must be sold separately	Cornerstone: property is used and marketed as one contiguous parcel; tax parcels are arbitrary lines and several parcels are unbuildable alone	Held: Not separate and distinct tracts; single sale permissible
Whether the foreclosure notice misstated the amount due under Minn. Stat. §580.04(a)(3)	Leeco: mortgage capped the line of credit at $1.2M, so the notice claiming ~$4.18M was misstatement	Cornerstone: mortgage secured all obligations of grantor/borrower, not just the $1.2M line; Leeco disclosed ~ $4.8M owed — $4.18M was supportable	Held: Notice did not misstate amount due; no invalidating overstatement

Frieler v. Carlson Mktg. Grp., 751 N.W.2d 558 (Minn. 2008) (summary-judgment standard discussion)
Osborne v. Twin Town Bowl, Inc., 749 N.W.2d 367 (Minn. 2008) (de novo review on appeal of summary judgment)
Hunter v. Anchor Bank, N.A., 842 N.W.2d 10 (Minn. App. 2013) (failure to sell separate parcels when required renders foreclosure void)
Business Bank v. Hanson, 769 N.W.2d 285 (Minn. 2009) (distinguishing amount owed on note from amount secured by mortgage)
DLH, Inc. v. Russ, 566 N.W.2d 60 (Minn. 1997) (standard for genuine issue of material fact)
Butterfield v. Farnham, 19 Minn. 85 (Minn. 1872) (overstatement in foreclosure notice may void sale where fraudulent or deters bidders)
Worley v. Naylor, 6 Minn. 192 (Minn. 1861) ("distinct" tracts requires physical separation, not mere legal subdivisions)
Lalor v. McCarthy, 24 Minn. 417 (Minn. 1878) (adjoining lots used as one unit treated as single tract)