U.S. Bank National Association v. Thompson

── U.S. Bank National Association v. Thompson ── Court: Appellate Court of Illinois Date: May 08, 2026 Category: General 2026 IL App (1st) 241593-U No. 1-24-1593 Order filed May 8, 2026 Sixth Division NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT U.S. BANK NATIONAL ASSOCIATION, ) Appeal from the Circuit Court ) of Cook County. ) Plaintiff-Appellee, ) v. ) No. 19 CH 05814 ) GWENDOLYN THOMPSON; ROBERT ) BARNEY, ) The Honorable ) James T. Derico, Defendants-Appellants. ) Judge, presiding. JUSTICE HYMAN delivered the judgment of the court. Presiding Justice C.A. Walker and Justice Pucinski concurred in the judgment. ORDER ¶1 Held: Affirming trial court order confirming judicial sale. ¶2 U.S. Bank, N.A. filed a mortgage foreclosure complaint against Gwendolyn Thompson and her husband, Robert Barney, after they became delinquent on their loan. The trial court entered an order of default against Barney, a summary judgment order against Thompson, and a judgment of foreclosure for U.S. Bank. Barney appealed pro se, which this court dismissed  1-24-1593 for lack of jurisdiction. Meanwhile, the trial court confirmed the judicial sale and entered a deficiency judgment. ¶3 Barney again appeals pro se arguing the trial court (i) lacked jurisdiction to confirm the foreclosure sale while his appeal was pending and (ii) failed to follow the Uniform Commercial Court, a federal executive order, and the Land Patent Act. We affirm. Barney’s first appeal did not divest the trial court of jurisdiction to confirm the judicial sale because the order appealed from was not final and appealable. Further, Barney waived his UCC and executive order arguments by failing to raise them in the trial court and his sovereign citizen arguments are without merit, so we do not address them. ¶4 Background ¶5 Gwendolyn Thompson took out a loan from Park National Bank, secured by a mortgage on her home. Thompson’s husband, Robert Barney, signed the mortgage solely to waive his homestead rights. U.S. Bank purchased Park National Bank’s assets under a FDIC receivership and sued to foreclose when Thompson failed to make timely payments. Thompson and Barney initially had counsel, but their counsel withdrew and they proceeded pro se. ¶6 Non-attorney Sharon Renee-Lloyd filed a “special appearance” as a “certified land patent holder *** communicating on behalf of the land,” a theory espoused by the “sovereign citizen movement.” Renee-Lloyd also filed an answer to the foreclosure complaint, a motion to dismiss, and several other documents. The trial court construed some of Renee-Lloyd’s filings as a petition to intervene, which it denied, along with her motion to dismiss. And the court granted U.S. Bank’s motion to strike Renee-Lloyd’s other filings.