In 2012, the Supreme Court of Michigan issued an opinion in Kim v. JPMorgan Chase Bank, N.A. (“Kim”). The primary focus of the decision at that time was the Court’s analysis which stated that in order to set aside a foreclosure sale when a mortgagee or servicer violates the Michigan foreclosure by advertisement statute, the borrower must show actual prejudice caused by the violation. At the time, it was deemed to be a positive ruling for mortgage holders and servicers. Now, f