Code of Alabama

Ala. Code § 6-2-32 (2026)

Commencement of Actions - Twenty Years.

✓ official Alabama Legislature (ALISON) text, current July 2026
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Within 20 years, actions upon a judgment or decree of any court of this state, of the United States, or of any state or territory of the United States must be commenced.

(Code 1852, §2475; Code 1867, §2899; Code 1876, §3224; Code 1886, §2613; Code 1896, §2794; Code 1907, §4833; Code 1923, §8942; Code 1940, T. 7, §19.)

Notes of Decisions
Cited in 10 cases (3 in the last 5 years), 1985–2025 · leading case: Clay v. Clay, 255 So. 3d 238 (Ala. Civ. App. 2017).
Clay v. Clay, 255 So. 3d 238 (Ala. Civ. App. 2017). · cites it 4× “, had reached the age of majority on June 30, 1995, and that, therefore, the former wife's pleading was barred by the statute of limitations found in § 6-2-32, Ala. Code 1975, which provides: "Within 20 years, actions upon a judgment or decree of any court of this state, of the…”
Willey v. Willey, 203 So. 3d 875 (Ala. Civ. App. 2016). · cites it 3× “The former husband argues that, because the former wife’s action for unpaid alimony was commenced on September 19, 2014, over 20 years after the entry of the December 12, 1975, divorce judgment, her petition was barred by the operation of § 6-2-32. We note, however, that “each…”
Vagenas v. Cont'l Gin Co., 789 F. Supp. 1137 (M.D. Ala. 1992). · cites it 2× “Vagenas further argues that the applicable limitations period is 20 years as provided in § 6-2-32, Code of Alabama. Section 6-2-32 states that “within 20 years, actions upon a judgment or decree of any court of this state, of the United States or of any state or territory of the…”
Powles v. Kandrasiewicz, 886 F. Supp. 1261 (W.D.N.C. 1995). “at 362 (emphasis added); see also Ala.Code Ann. § 6-2-32 and Second Nat’l Bank v.”
Bodenhamer v. Wooten, 595 S.E.2d 592 (Ga. Ct. App. 2004). “Judgments in Georgia become dormant after seven years with the possi *736 bility of revival up to three years thereafter (see OCGA §§ 9-12-60 (a) (1); 9-12-61), 1 and judgments become dormant in Alabama after twenty years (see Code of Ala. § 6-2-32). Therefore, Alabama law would…”
Vagenas v. Cont'l Gin Co., 988 F.2d 104 (11th Cir. 1993). “Reading § 6-2-32 in light of the treaty, a Greek national with a foreign judgment must be given the same twenty year time frame to enforce the judgment as is available to the United *107 States citizen seeking to enforce a sister state judgment in Alabama.”
Anatharaju v. Gastrointestinal Specialists, P.C. (N.D. Ala. 2022). · cites it 8× “Count One of the Complaint Satisfies the 20-Year Statute of Limitations Set Forth in Alabama Code § 6-2-32 Count One of the Complaint presents a Bill to Enforce Creditor’s Judgment Pursuant to Alabama Code § 6-6-180 and to Pierce the Corporate Veil of GIS.”
Allie Constr., Inc. v. Debra Mosier, as Pers. Rep. of the Est. of Willard Mosier (Ala. 2023). · cites it 4× “In short, Debra would add a requirement that a plaintiff effect service before the statute of limitations expires to properly commence an action under § 6-2-32. But that is not how we evaluate whether a statute of limitations has been met.”
Hibernia Nat'l Bank v. Morrison, 466 So. 2d 948 (Ala. 1985). · cites it 3× “519 (1850), as well as Code of 1975, §§ 6-2-32, 6-9-191, 6-9-210, and 6-9-211.”
Mariner Health Care Mgmt. Co. v. Sovereign Healthcare Holdings, LLC (Ga. Ct. App. 2025). “1993) (relying on Ala. Code § 6-2-32 which expressly provides a 20-year statute of limitation for “actions upon a judgment”); Belleville v.”
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