Bankruptcy.
Costs incurred by the Trustee in maintaining the property prior to the abandonment of the interest by the secured creditor can be surcharged to the secured creditor absent evidence of direct benefit.
http://www.ca5.uscourts.gov/opinions/pub/14/14-41463-CV0.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.