New Milford Sav. Bank v. Jajer

In New Milford Sav. Bank v. Jajer, 244 Conn. 251, 708 A.2d 1378, 1385 (Conn. 1998), the Connecticut court relied on the Restatement (Third) of Property: When foreclosing a mortgage covering more than one parcel of real estate, upon the motion or application of the holder of a subordinate interest protected by this section, the mortgagee must proceed against the parcels in the following order: (1) parcels on which no subordinate interests exist are foreclosed upon before parcels on which subordinate interests exist; and (2) as among parcels on which subordinate interests exist, those with subordinate interests created more recently are foreclosed upon before those with subordinate interests created at a more remote time. (Id. at 1385, n.18.)