In Select Commercial Assets LLC v Carrothers, the mortgagor challenged foreclosure of a mortgage on the basis that the foreclosing entity did not hold the underlying promissory note. In Residential Funding Co. v Saurman, the Michigan Supreme Court held, in the foreclosure by advertisement context, that a mortgagee did not need to hold the underlying note in order to foreclose the mortgage by advertisement; it was only necessary that the mortgage be in default. The Carrothers opinion extended that holding to judicial foreclosures.