This page explains New York law. Three different clocks run on a New York money judgment, and they are easy to confuse: how long it is a lien on real property, how long the creditor can enforce it, and how fast interest adds to it. For an overview of what a creditor can do with a judgment, see what happens after a money judgment is entered against you in New York. KOR Law LLP's post-judgment defense practice represents judgment debtors in these matters.
The three clocks at a glance
| Clock | Length | What extends or restarts it |
|---|---|---|
| Lien on real property (CPLR 5203(a)) | From docketing in the county until 10 years after the judgment-roll was filed | A renewal judgment (CPLR 5014); a court-ordered extension for time the creditor was stayed or to finish an execution sale (CPLR 5203(b)) |
| Enforcement (CPLR 211(b)) | Presumed paid 20 years after the creditor was first entitled to enforce it | A written, signed acknowledgment or any payment, including property taken by levy, starts a new 20 years |
| Interest (CPLR 5004) | Runs until paid | 9% a year; 2% a year on a judgment arising out of a consumer debt where a natural person is the defendant |
How do the clocks run over the life of a judgment?
- Entry and docketing. Immediately after the judgment-roll is filed, the clerk dockets the money judgment (CPLR 5018(a)). The real property lien in that county starts with docketing.
- The first ten years. The creditor can use restraining notices, executions and the other enforcement devices; an execution may issue at any time before the judgment is satisfied or vacated (CPLR 5230(b)).
- Year nine to ten. The creditor may start an action for a renewal judgment during the year before ten years from the first docketing run out (CPLR 5014).
- Year ten. Without a renewal judgment or a court-ordered extension, the lien ends ten years after the judgment-roll was filed (CPLR 5203(a), (b)). The judgment itself does not.
- After year ten. A sheriff can still levy on real property by filing a notice of levy with the county clerk (CPLR 5235).
- Year twenty. The judgment is presumed paid unless the debtor acknowledged it in a signed writing or made a payment within the twenty years (CPLR 211(b)).
How does the ten-year lien work?
Under CPLR 5203(a), once a judgment is docketed with the clerk of the county where you own real property, a transfer of your interest in that property is not effective against the judgment creditor until ten years after the judgment-roll was filed. That is what makes a judgment show up in a title search and hold up a sale or refinance; the ways to clear it are in whether you can sell or refinance property with a judgment lien on it. A judgment can be docketed in any other county by filing a transcript, with the same effect there (CPLR 5018(a)).
The lien is county by county. A judgment from the Civil Court or another lower court becomes a lien on real property only after a transcript is filed with the county clerk (CPLR 5018(a); NY Courts CourtHelp, Transcript of Judgment). In Brooklyn, docketed money judgments are searched and satisfied at the Kings County Clerk's office; the windows and records are described on our page for foreclosure and judgment defense in Brooklyn (Kings County).
The lien ending is not the same as the judgment ending. After ten years, a sheriff can still levy on the debtor's real property under an execution by filing a notice of levy with the county clerk (CPLR 5235), and CPLR 5203(a) gives that levy priority from its filing until the execution is returned. How the sheriff then sells real property is set out in what a sheriff can seize under a property execution in New York.
What is a renewal judgment?
A creditor who wants the lien to continue can sue on the judgment itself. CPLR 5014 allows an action on a money judgment between the original parties once ten years have passed since it was first docketed, and it lets the creditor start that action during the year before the ten years run out. The new judgment is called a renewal judgment, and its lien takes effect when the ten years from the original docketing expire, so the lien continues without a gap. The same section also allows an action on the judgment where the original was entered on default and the summons was not personally delivered, or where the court orders it on motion.
Short of renewal, CPLR 5203(b) lets the court, on the creditor's motion with notice to the debtor by personal service or registered or certified mail, extend the lien beyond ten years, but only for as long as the creditor was stayed from enforcing, or for the time needed to finish an execution sale where the execution was delivered to the sheriff before the ten years ended.
When is a judgment presumed paid?
CPLR 211(b) says a money judgment is presumed paid and satisfied twenty years after the creditor was first entitled to enforce it. The presumption is conclusive, with one important exception: it does not protect a person who, within the twenty years, acknowledged the debt in a signed writing or made a payment on it. In that case the judgment is presumed paid twenty years after the last acknowledgment or payment. Property the creditor obtained by an enforcement order or a levy counts as a payment, unless the person charged shows it did not include property he claimed.
For a debtor, the practical point is that a partial payment or a signed letter admitting the debt can start a new twenty years. That is worth knowing before agreeing to a payment plan on a very old judgment.
How much interest does a judgment add?
CPLR 5004 sets the rate at 9% a year unless another statute provides otherwise. Since a 2021 amendment, the rate is 2% a year in an action arising out of a consumer debt where a natural person is the defendant. "Consumer debt" means an obligation of a natural person arising from a transaction primarily for personal, family or household purposes, including a consumer credit transaction. The 2% rate also applies, from the amendment's effective date, to any unpaid part of a consumer debt judgment entered before it (CPLR 5004(a)). When the rate changes while a restraint or execution is in place, the creditor must issue an amended restraining notice or execution showing the new rate (CPLR 5222(a), 5230(a)).
| Judgment amount | At 9% a year | At 2% a year (consumer debt, individual defendant) |
|---|---|---|
| $25,000 | $2,250 | $500 |
| $100,000 | $9,000 | $2,000 |
| $500,000 | $45,000 | $10,000 |
Whether a judgment arises out of a consumer debt turns on what the original transaction was for. A personal guaranty of a business loan, for example, raises a different question than a credit card balance, so the rate stated on a restraining notice that freezes a bank account or on an execution is worth checking against the underlying claim.
What changes the answer for an old judgment?
- A signed acknowledgment or a payment. Either one, made within the twenty years, starts a new twenty-year period, and property taken by levy counts as a payment (CPLR 211(b)).
- A stay. If the creditor was stayed from enforcing, the court may extend the lien by that time on notice to the debtor (CPLR 5203(b)).
- A default with substituted service. Where the judgment was entered on default and the summons was not personally delivered, the creditor may sue on it before ten years pass (CPLR 5014(2)). The same facts may give the debtor a way to reopen it; see whether you can undo a default judgment in New York.
- The debtor's death. A judgment entered after the debtor's death is not a lien that defeats a later transfer of the debtor's real property (CPLR 5203(a)(4)).
- A judgment from another state or a federal court. Once filed with a county clerk, it is treated like a New York Supreme Court judgment and has the same effect (CPLR 5018(b), 5402(b)); see how out-of-state and federal judgments are enforced in New York.
- A support judgment. An action to enforce an order or judgment for support, alimony or maintenance has its own twenty-year limit, counted from the date of a default in payment (CPLR 211(e)).
None of these is the same as the separate six-year limit for starting a mortgage foreclosure (CPLR 213(4)), which is explained in how long a lender has to foreclose in New York. The six-year limit for suing on a note or guaranty in the first place is covered in how long a lender has to sue on a note or guaranty in New York.
For example: a judgment from 2017
For example, imagine a credit card judgment entered and docketed against a Brooklyn homeowner on June 1, 2017. (This is a made-up illustration, not a real client or result.) The lien on her house runs until June 1, 2027, ten years after the judgment-roll was filed. Because the debt was a consumer debt and she is a natural person, interest that accrued at 9% switched to 2% on the unpaid balance from the effective date of the 2021 amendment, and any restraint or execution in place at the time had to be amended to show the new rate.
In 2020, a sheriff's levy on her bank account collected part of the judgment. Under CPLR 211(b) that counts as a payment, so the twenty years now run from 2020, not 2017. In November 2026, inside the final year before the lien expires, the creditor serves a summons in an action on the judgment. If a renewal judgment is entered, its lien starts on June 1, 2027, the day the original lien ends. She answers the summons rather than ignoring it, checks the interest figures on every notice, and before agreeing to any payment plan reviews what a signed acknowledgment would do to the twenty-year clock.
Common mistakes with old judgments
- Treating the end of the lien as the end of the judgment. After ten years, a sheriff can still levy on real property by filing a notice of levy (CPLR 5235).
- Signing a letter that admits the debt. A signed written acknowledgment starts a new twenty years (CPLR 211(b)).
- Making a small "good faith" payment. Any payment, even partial, does the same (CPLR 211(b)).
- Ignoring a renewal summons. A renewal judgment comes from a new action under CPLR 5014, with its own deadline to appear and answer (CPLR 320).
- Accepting the interest rate on the notice. A consumer debt judgment against an individual carries 2%, not 9% (CPLR 5004).
- Paying without clearing every county. If the judgment was docketed elsewhere by transcript, the creditor must file a clerk's certificate in each county after full payment (CPLR 5020(d)).
What to do this week
- Get the docket entry for the judgment from the county clerk and note the date the judgment-roll was filed.
- Count ten years from that date for the lien, and mark the year before it, when a renewal action can start.
- List every payment, levy and signed letter since the judgment, with dates, to work out the twenty-year clock.
- Check whether the debt was a consumer debt and which interest rate the latest notice uses.
- Find out whether the judgment was docketed in other counties by transcript.
- Bring these papers, organized with our judgment enforcement consultation checklist, to a lawyer before signing or paying anything.
Frequently asked questions
Can a creditor still collect after ten years?
Yes. The ten years limit the real property lien, not the judgment. An execution may issue at any time before the judgment is satisfied or vacated (CPLR 5230(b)), and the judgment is not presumed paid until the twenty-year mark (CPLR 211(b)). The limits on wage collection are in how much of your wages a creditor can take.
Does the twenty-year presumption apply automatically?
It is raised as a defense. CPLR 211(b) says the presumption may be used under an allegation that the action was not started within the time limited.
Does a judgment become a lien on property I buy later?
The court system's guide says a docketed judgment becomes a lien on the debtor's land or land he or she buys in that county. The lien still lasts only until ten years after the judgment-roll was filed (CPLR 5203(a)).
What happens when the judgment is paid?
The creditor must file a satisfaction-piece or partial satisfaction-piece with the clerk and mail a copy to the debtor within ten days of filing (CPLR 5020(a)). If a fully paid judgment is not satisfied of record within twenty days, the creditor faces a penalty of $100 for a judgment under $5,000 or $500 for a larger one, recoverable by the debtor (CPLR 5020(c)).
Can the creditor take exempt property during all those years?
No. Exemptions apply for the whole life of a judgment, whatever its age; see what property a New York judgment creditor cannot take.
What if the creditor cannot be found to sign a satisfaction?
If the judgment has been paid but you cannot get a satisfaction-piece, the court can order the clerk to enter satisfaction on motion (CPLR 5021(a)(2)). Within ten years after entry, the creditor's attorney of record may also sign the satisfaction-piece (CPLR 5020(b)).
