Code of Alabama
Ala. Code § 6-9-191 (2026)
Judgment Presumed Satisfied 10 Years After Entry or Execution.
✓ official Alabama Legislature (ALISON) text, current July 2026
If 10 years have elapsed from the entry of the judgment without issue of execution or if 10 years have elapsed since the date of the last execution issued, the judgment must be presumed satisfied, and the burden of proving it not satisfied is upon the plaintiff.
(Code 1852, §2419; Code 1867, §2830; Code 1876, §3174; Code 1886, §2923; Code 1896, §1930; Code 1907, §4154; Code 1923, §7871; Code 1940, T. 7, §582.)
Notes of Decisions
Cited in 16
cases (3 in the last 5 years), 1985–2025 · leading case: Hardy v. Johnson, 245 So. 3d 617 (Ala. Civ. App. 2017).
Hardy v. Johnson, 245 So. 3d 617 (Ala. Civ. App. 2017). “otion, he argued, among other things, that the trial court had erred by failing to order the mother, who was incarcerated in a federal prison on the date of the June 2016 judgment, to pay child support and that certain of the child-support installments that the trial court had…”
Willey v. Willey, 203 So. 3d 875 (Ala. Civ. App. 2016). “In her postjudgment motion, the former wife cited Ala.Code 1975, § 6-9-191, which addresses the revival of judgments and provides that, “[i]f 10 years have elapsed from the entry of the judgment without issue of execution or if 10 years have elapsed since the date of the last…”
Alred v. State Ex Rel. Hill, 603 So. 2d 1082 (Ala. Civ. App. 1992). “The father bases his argument on Ala.Code 1975, § 6-9-191, which states that "[i]f 10 years have elapsed from the entry of the judgment without issue of execution or if 10 years have elapsed since the date of the last execution issued, the judgment must be presumed satisfied,…”
Davis Int'l, Inc. ex rel. Patel v. Berryman, 730 So. 2d 242 (Ala. Civ. App. 1999). “In his motion, Berryman asserted that the judgment against him had “lapsed” on January 15, 1996, and that it had not been properly revived; relying on § 6-9-191, Ala.Code 1975, Berryman requested that the court enter an order showing that the judgment had been “satisfied.”
Williams v. Hobson, 5 So. 3d 630 (Ala. Civ. App. 2008). “We note that Ala.Code 1975, § 6-9-191, provides that a rebuttable presumption that a judgment has been satisfied will arise after 10 years has elapsed from the entry of a judgment without issue of execution.”
Mollohan v. Jelley, 925 So. 2d 207 (Ala. Civ. App. 2005). “Thus, the payments are not subject to the presumption of satisfaction found in section 6-9-191." (Emphasis added.)”
Derringer v. Beadlescomb, 537 So. 2d 34 (Ala. Civ. App. 1988). “§ 6-9-191, Code 1975. We disagree. This argument rests on the assumption that a child support payment becomes a “final judgment” on the date it falls due.”
Powles v. Kandrasiewicz, 886 F. Supp. 1261 (W.D.N.C. 1995). “"); see also Ala. Code Ann. 6-9-191 (1975).”
Tiffany Monique Lewis (Bankr. M.D. Ala. 2025). “The Objection to Claim appears to alternatively assert that: a) the HMC Claim is presumed satisfied under Ala. Code § 6-9-191 (not that the HMC Claim was paid); or b) the HMC Claim is unenforceable pursuant to Ala.”
Hines v. Cunningham, 622 So. 2d 395 (Ala. Civ. App. 1993). “The father also cites § 6-9-191, Code 1975, which provides that: “If ten years have elapsed from the entry of the judgment without issue of execution, or if 10 years have elapsed since the date of the last execution issued, the judgment must be presumed satisfied, and the burden…”
Tiffany Monique Lewis (Bankr. M.D. Ala. 2025). “TheObjectiontoClaimappearstoalternativelyassertthat: a)the HMCClaimispresumedsatisfiedunderAla.Code§6-9-191(notthattheHMCClaim was paid); or b) the HMC Claim is unenforceable pursuant to Ala.”
Allen v. First Alabama Bank (In re Sintz), 162 B.R. 572 (Bankr. S.D. Ala. 1993). “”)-, § 6-9-191 (“If 10 years have elapsed from the entry of the judgment without issue of execution .”
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