Legal Insights

Illinois’ First District Court of Appeals recently affirmed an order dismissing BMO Bank’s (“BMO”) action to foreclose a mortgage which secured a $100,000 line of credit (“LOC”) issued in favor of James Zbroszczyk. BMO Bank N.A. v. Zbroszczyk, 2025 IL App (1st) 241333 (June 18, 2025). The equity LOC was a revolving line which allowed Zbroszczyk to draw up to $100,000 and make re-occurring draws on any amounts he paid back as long as he did not exceed the $100,000 LOC.

Judge James T. Derico, Jr., of the Chancery Division in Cook County recently reconsidered his prior order striking borrower Anthony Andrews’ cross-motion for summary judgment against lender, The Bank of New York Mellon (BNY Mellon). The Bank of New York Mellon, etc., v. Anthony D. Andrews, Cook County Illinois Circuit Court Case No. 2012 CH 41128 (May 19, 2025). Although agreeing to reconsider its prior ruling, the court refused to modify its ruling.

Earlier this month the Illinois Supreme Court adopted a new rule, Rule 300, pertaining to petitions for the recovery of attorneys’ fees, made minor revisions to Rule 795, pertaining to continuing legal education, and made significant amendments to two Rules of Professional Conduct, Rules 1.6 and 7.2, to define and address the relatively recent development of “intermediary connecting services” (ICS) used by attorneys to generate new business.