8th Circuit Sanctions Foreclosure Defense Lawyer


Mustafa v. Bank of America, NA, Court of Appeals, 8th Circuit 2013 – Google Scholar.

The 8th Circuit has sanctioned a foreclosure defense lawyer named William Butler. Butler filed a number of cases against banks and mortgage servicing companies alleging that they did not have the right to foreclose because they did not own the promissory note.

Courts, including Illinois courts, have rejected this “show me the note” theory. Mr. Butler has continued to litigate this issue long after the courts ran out of patience with him. In the past year, I have seen numerous sanctions cases against Mr. Butler. I don’t understand why clients keep hiring him.

Edward X. Clinton, Jr.

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