Due the declining economy, foreclosures are growing at an unprecedented rate, one which is extremely high. Alongside the high number of foreclosures, a comparably high number of foreclosure cases are taking place as well. Not all foreclosures end in court, but in those that do, the process can be fairly complicated. In one type of foreclosure, by power of judicial sale, the foreclosure will always end in court, with a judge taking control of the sale. During this type of foreclosure, the process will be handled under the supervision of the court, who will appropriate the proceeds from the sale to the proper parties, including the primary lender and other lien holders. Even in foreclosures other than judicial sale, lawsuits can still arise when the borrower determines that the unlawful procedures have been used. If, for example, the mortgage being foreclosed upon consisted of unlawful terms, the borrower can present the case to a judge using legal action known as wrongful foreclosure.