In a ruling on February 28, 2013, the U.S. District Court for the Central District of Illinois reversed the February 29, 2012 order of the U.S. Bankruptcy Court for the Central District of Illinois allowing a bankruptcy trustee to avoid an Illinois mortgage as to unsecured creditors for lack of “constructive notice” because the mortgage did not expressly state the maturity date of and interest rate on the underlying debt (In Re Crane, Case 12-2146, U.S. Dist. Ct., C.D. IL, February 28, 2013).

In a ruling on February 29, 2012, the U.S. Bankruptcy Court for the Central District of Illinois allowed a bankruptcy trustee to avoid an Illinois mortgage as to other creditors of the estate because the mortgage failed to expressly state the maturity date of and interest rate on the underlying debt (In Re Crane, Case 11-90592, U.S. Dist Ct, C.D. IL, February 29, 2012).

On January 19, 2012, the 7th Circuit Court of Appeals issued an opinion in In re River East Plaza, LLC , 2012 WL 169760 (7th Cir. January 19, 2012), affirming an order by the U.S. Bankruptcy Court for the Northern District of Illinois, Eastern Division, granting an undersecured creditor's motion to lift the automatic stay and dismissing the debtor's single asset real case. The debtor attempted to defeat the mortgagee's motion to lift the automatic stay by proposing a "cramdown" Chapter 11 plan of reorganization.