National Packaging Corp. v. Belmont

National Packaging Corp. (plaintiff) obtained a judgment against Michael Bolan but recorded it under the misspelled name "Bolen"; because of this error, National received no notice when Bolan's ex-wife Elaine Belmont (defendant) foreclosed on and purchased Bolan's property, which she later sold to the DeCamps (defendants). National then tried to foreclose based on its own judgment lien, and the trial court granted the defendants summary judgment on the ground that National's misspelled recording did not give constructive notice; National appealed, urging application of the idem sonans doctrine to excuse the misspelling.