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735 ILCS 5/12-108

Limitation on enforcement

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(735 ILCS 5/12-108) (from Ch. 110, par. 12-108)
    Sec. 12-108. Limitation on enforcement.
    (a) Except as herein provided, no judgment shall be enforced after the expiration of 7 years from the time the same is rendered, except upon the revival of the same by a proceeding provided by Section 2-1601 of this Act; but real estate, levied upon within the 7 years, may be sold to enforce the judgment at any time within one year after the expiration of the 7 years. A judgment recovered in an action for damages for an injury described in Section 13-214.1 may be enforced at any time. Child support judgments, including those arising by operation of law, may be enforced at any time. Consumer debt judgments may be revived or enforced in accordance with subsection (a-10) of Section 2-1602.
    (b) No judgment shall be enforced against a police officer employed by a municipality if the corporate authority of the municipality files with the clerk of the court in which the judgment was entered a statement certifying: (1) such police officer was employed by the municipality and was within the scope and course of his employment at the time of the occurrence giving rise to the action in which the judgment is entered and (2) the municipality indemnifies the police officer in the amount of the judgment and interest thereon. In such event, the judgment creditor may enforce the judgment against the municipality in the same manner and to the same extent as if the municipality were the judgment debtor.
    (c) If a judgment or a consumer debt judgment becomes dormant during the pendency of an enforcement proceeding against wages under of Part 14 of Article II or Part 8 of Article XII, the enforcement may continue to conclusion if the enforcement is done under court supervision and includes a wage deduction order or turn over order and is against an employer, garnishee, or other third party respondent.
(Source: P.A. 104-120, eff. 1-1-26.)

    
Notes of Decisions
Cited in 35 cases (9 in the last 5 years), 1996–2025 · leading case: Sarkissian v. Chicago Board of Education
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Sarkissian v. Chicago Board of Education (2002) ill · cites it 2× “See 735 ILCS 5/12-108 (West 2000) (prohibiting enforcement of judgments after the expiration of seven years).”
Dexia Credit Local v. Rogan (2010) ca7 · cites it 2× “735 ILCS 5/12-108(a) (“Except as herein provided, no judgment shall be enforced after the expiration of 7 years from the time the same is rendered, except upon the revival of the same by a proceeding provided by Section 2-1601 of this Act.”
Panos Trading LLC v. Forrer (2023) illappct · cites it 4× “” 735 ILCS 5/12-108 (West 2018). Section 2-1601 3 directs us to section 2-1602 of the Code, which provides, in part, that a dormant judgment may be revived at any time within 20 years after its entry by serving a petition to revive the judgment and entering a court order for…”
In Re Marriage of Saputo (2006) illappct · cites it 6× “We find that Caroline's petition was not time-barred in light of the July 1, 1997, amendment to section 12-108(a) of the Code (735 ILCS 5/12-108(a) (West 2004)), which provides that child support judgments may be enforced at any time.”
Schindler v. Watson (2017) illappct · cites it 3× “735 ILCS 5/12-108 (West 2004). Section 12-108 states in pertinent part: “Except as herein provided, no judgment shall be enforced after the expiration of 7 years from the time the same is rendered, except upon the revival of the same by a proceeding provided by Section 2-1601 of…”
Loretta Klump v. J. David Duffus, Jr., Law Offices of Dixon, Duffus & Doub, a Partnership, and Accident and Injury Refer (1996) ca7 “See 735 ILCS 5/12-108, 5/13-218. Therefore, in the district court’s view, Eaves’s current ability to pay the judgment was irrelevant because his financial position could change during the twenty-year period.”
Del Prado v. BN DEVELOPMENT CO., INC. (2010) ca5 “735 ILCS 5/12-108(a). This is required even though a judgment does not prescribe until the expiration of twenty years after its entry.”
Golden v. Puccinelli (2016) illappct · cites it 3× “” 735 ILCS 5/12-108 (West 2014). Moreover, section 13-218 provides that the statute of limitations to file a petition to revive a judgment is “no later than 20 years next after the date of entry of such judgment.”
Douglas Kelley v. Steven Stevanovich (2022) ca7 “The district court rejected Ste- vanovich’s argument that the five-year statute of limitations for embezzlement applied, accruing from the dates of the wine purchases. See 735 ILCS 5/13-205. Instead, it applied the seven-year statute of limitations for supplementary proceed-…”
In re Contreras (2017) ilnb · cites it 2× “Pursuant to 735 ILCS 5/12-108, dormant judgments are not enforceable until they are revived.”
Burman v. Snyder (2014) illappct · cites it 3× “¶6 The trial court denied Burman leave to respond to Snyder’s motion to dismiss, stating it had considered the Rule 103(b) issues on its own motion, and entered an order finding that Burman’s 1998 petition to revive the judgment, the only petition filed, could not, under section…”
Dexia Credit Local v. Rogan (2009) ilnd “735 ILCS 5/12-108(a). Dexia’s turnover motion with respect to the Rogan domestic trusts was filed less than two years after entry of judgment against Peter Rogan.”
Show all 35 citing cases →
— 735 ILCS 5/12-108(a) — 23 cases
Dexia Credit Local v. Rogan (2010) ca7 “735 ILCS 5/12-108(a) (“Except as herein provided, no judgment shall be enforced after the expiration of 7 years from the time the same is rendered, except upon the revival of the same by a proceeding provided by Section 2-1601 of this Act.”
Sarkissian v. Chicago Board of Education (2002) ill “See 735 ILCS 5/12-108 (West 2000) (prohibiting enforcement of judgments after the expiration of seven years).”
Panos Trading LLC v. Forrer (2023) illappct “” 735 ILCS 5/12-108 (West 2018). Section 2-1601 3 directs us to section 2-1602 of the Code, which provides, in part, that a dormant judgment may be revived at any time within 20 years after its entry by serving a petition to revive the judgment and entering a court order for…”
In Re Marriage of Saputo (2006) illappct “We find that Caroline's petition was not time-barred in light of the July 1, 1997, amendment to section 12-108(a) of the Code (735 ILCS 5/12-108(a) (West 2004)), which provides that child support judgments may be enforced at any time.”
Del Prado v. BN DEVELOPMENT CO., INC. (2010) ca5 “735 ILCS 5/12-108(a). This is required even though a judgment does not prescribe until the expiration of twenty years after its entry.”
— 735 ILCS 5/12-108(c) — 1 case
Urban v. Blewitt (2025) illappct
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