A mortgagor alleging breach of the mortgagee's duty on sale must show more than that the sale was at an undervalue; the mortgagor must demonstrate a failure to act in good faith, with reasonable skill and care, or to take reasonably adequate steps to ensure a fair price. A price obtained after proper marketing is strong evidence of true market value and will generally defeat valuation evidence suggesting undervalue. The concept of 'special value' to the mortgagor is irrelevant to the assessment of whether a mortgagee has sold at an undervalue.
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