Wells Fargo Bank, NA v. Heritage Bank of Central Illinois, 984 N.E.2d 1186

Black Hawk obtained a 1994 judgment and recorded a memorandum of judgment in Tazewell County; Wells Fargo and Heritage later recorded mortages on the property.
Black Hawk revived its judgment in 2001 and recorded a revived memorandum in Tazewell County; Black Hawk again revived in 2008.
Wells Fargo filed a foreclosure in 2008; sale occurred in 2011 for $150,001 and proceeds were distributed $115,590.54 to Wells Fargo and $34,410.46 to Heritage.
The trial court (July 2, 2010) prioritized liens, finding Black Hawk had no lien in effect from June 5–15, 2001, to the 2001 revival period.
Dispute centers on whether Black Hawk’s lien lapsed under 735 ILCS 5/12-101, and thus whether Wells Fargo and Heritage had priority over Black Hawk.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Black Hawk's lien lapse in June 2001 under 12-101?	Wells Fargo argues Black Hawk’s lien expired June 5, 2001, so it lost priority.	Black Hawk argues revival within seven years and timely memorandum preserved lien.	Lapse; Black Hawk lost priority.
Is there appellate jurisdiction to review the July 2, 2010 lien-priority order?	Wells Fargo questions jurisdiction since order not listed in notice of appeal.	Black Hawk contends review is proper as a procedural step leading to final sale order.	We have jurisdiction to review the July 2, 2010 order.

JP Morgan Chase Bank v. Fankhauser, 383 Ill. App. 3d 254 (Ill. App. 2008) (finality and appealability of sale-confirmation order)
Knapp v. Bulun, 392 Ill. App. 3d 1018 (Ill. App. 2009) (interlocutory orders review upon final judgment)
Dunn v. Thompson, 174 Ill. App. 3d 944 (Ill. App. 1988) (creation of judgment lien is statutory, not common law)
Barth v. Kantowski, 409 Ill. App. 3d 420 (Ill. App. 2011) (strict compliance with section 12-101 for judgment liens)
Casey National Bank v. Roan, 282 Ill. App. 3d 55 (Ill. App. 1996) (lien attaches from filing memorandum in recorder's office)