Dan Cummings represented the Maine Credit Union League as amicus curiae in the case of KeyBank National Association v. Elizabeth E. Keniston et al., 2023 ME 38, in which the appellant successfully obtained vacation of the trial court’s dismissal of its foreclosure action based on the debtor’s estate being a necessary party.  The appellant’s position, supported by the League, was that foreclosure is an in rem action and that extinguishment of the ability to enforce the promissory note secured by the mortgage as personal liability of the maker of the note does not also extinguish a mortgagee’s right to realize on its collateral by foreclosure of the mortgage.