De Novo Review For Appeals Under Illinois Foreclosure Law

The standard of review of an appeal under the Illinois Foreclosure Law is de novo. But “it is foreseeable that in a case in which a trial court has held a full evidentiary hearing on a motion to appoint a receiver, this court could find that an abuse of discretion standard or a manifest weight of the evidence standard would be appropriate to review the lower court’s judgmental decision.”

Bank of America v. 108 N. Retail, No. 1-09-3523 (1st Dist. Illinois Appellate 3/31/10).