ILCS » Chapter 735 · Act 5
Illinois Compiled Statutes

735 ILCS 5/12-183 (2026)

Release of judgment

✓ current as of May 2026
Find cases: SyfertCases citing this section IL-ILGAilga.gov JustiaChapter on Justia CornellLII Search CasesGoogle Scholar
(735 ILCS 5/12-183) (from Ch. 110, par. 12-183)
    Sec. 12-183. Release of judgment.
    (a) Every judgment creditor, his or her assignee of record or other legal representative having received full satisfaction or payment of all such sums of money as are really due to him or her from the judgment debtor on any judgment rendered in a court shall, at the request of the judgment debtor or his or her legal representative, execute and deliver to the judgment debtor or his or her legal representative an instrument in writing releasing such judgment.
    (b) If the judgment creditor, his or her assigns of record or other legal representative to whom tender has been made of all sums of money due him or her from the judgment debtor including interest, on any judgment entered by a court, wilfully fails or refuses, at the request of the judgment debtor or his or her legal representative to execute and deliver to the judgment debtor or his or her legal representative an instrument in writing releasing such judgment, the judgment debtor may petition the court in which such judgment is of record, making tender therewith to the court of all sums due in principal and interest on such judgment, for the use of the judgment creditor, his or her executors, administrators or assigns, whereupon the court shall enter an order satisfying the judgment and releasing all liens based on such judgment.
    (c) For the recording of assignment of any judgment the clerk of the court in which such judgment is of record is allowed a fee of $2.
    (d) A satisfaction of a judgment may be delivered to the judgment debtor, his or her attorney or to the clerk of the court in which such judgment is of record.
    (e) The clerk shall not be allowed any fee for recording the satisfaction of judgment. The clerk of the court shall make appropriate notation on the judgment docket of the book and page where any release or assignment of any judgment is recorded.
    (f) No judgment shall be released of record except by an instrument in writing recorded in the court in which such judgment is of record. However, nothing contained in this Section affects in any manner the validity of any release of judgment made, prior to January 1, 1952, in judgment and execution dockets by the judgment creditor, his or her attorney, assignee or other legal representative.
    (g) The writ of audita querela is abolished and all relief heretofore obtainable and grounds for such relief heretofore available, whether by the writ of audita querela or otherwise, shall be available in every case by petition hereunder, regardless of the nature of the order or judgment from which relief is sought or of the proceeding in which it was entered. There shall be no distinction between actions and other proceedings, statutory or otherwise, as to availability of relief, grounds for relief or relief obtainable. The petition shall be filed in the same proceeding in which the order or judgment was entered and shall be supported by affidavit or other appropriate showing as to matters not of record. All parties to the petition shall be notified as provided by rule.
    (h) Upon the filing of a release or satisfaction in full satisfaction of judgment, signed by the party in whose favor the judgment was entered or his or her attorney, the court may vacate the judgment, and dismiss the action.
    (i) Any judgment arising out of an order for support shall not be a judgment to the extent of payments made as evidenced by the records of the Clerk of the Circuit Court or State agency receiving payments pursuant to the order. In the event payments made pursuant to that order are not paid to the Clerk of the Circuit Court or a State agency, then any judgment arising out of each order for support may be released in the following manner:
        (1) A Notice of Filing and an affidavit stating that
    
all installments of child support required to be paid pursuant to the order under which the judgment or judgments were entered have been paid shall be filed with the office of the court or agency entering said order for support, together with proof of service of such notice and affidavit upon the recipient of such payments.
        (2) Service of such affidavit shall be by any means
    
authorized under Sections 2-203 and 2-208 of the Code of Civil Procedure or under Supreme Court Rules 11 or 105(b).
        (3) The Notice of Filing shall set forth the name and
    
address of the judgment debtor and the judgment creditor, the court file number of the order giving rise to the judgment and, in capital letters, the following statement:
        YOU ARE HEREBY NOTIFIED THAT ON (insert date) THE
    
ATTACHED AFFIDAVIT WAS FILED IN THE OFFICE OF THE CLERK OF THE CIRCUIT COURT OF .... COUNTY, ILLINOIS, WHOSE ADDRESS IS ........, ILLINOIS. IF, WITHIN 28 DAYS OF THE DATE OF THIS NOTICE, YOU FAIL TO FILE AN AFFIDAVIT OBJECTING TO THE SATISFACTION OF THE STATED JUDGMENT OR JUDGMENTS IN THE ABOVE OFFICE, THE SAID JUDGMENTS WILL BE DEEMED TO BE SATISFIED AND NOT ENFORCEABLE. THE SATISFACTION WILL NOT PREVENT YOU FROM ENFORCING THE ORDER FOR SUPPORT THROUGH THE COURT.
        (4) If no affidavit objecting to the satisfaction of
    
the judgment or judgments is filed within 28 days of the Notice described in paragraph (3) of this subsection (i), such judgment or judgments shall be deemed to be satisfied and not enforceable.
(Source: P.A. 99-744, eff. 8-5-16.)


 
    (735 ILCS 5/Art. XII Pt. 2 heading)
Part 2. Trial of Right of Property

    
Notes of Decisions
Cited in 15 cases (6 in the last 5 years), 1999–2025 · leading case: Süd Fam. Ltd. P'ship v. Otto Baum Co., 2024 IL App (4th) 220782 (Ill. App. Ct. 2024).
Sort: Relevance Newest Treatment
Süd Fam. Ltd. P'ship v. Otto Baum Co., 2024 IL App (4th) 220782 (Ill. App. Ct. 2024). “The record shows Süd’s petition was filed pursuant to section 12-183(b) of the Code (735 ILCS 5/12-183(b) (West 2018)) and asked the trial court to enter an order (1) holding that the chancery judgments had been satisfied and (2) “releasing those judgments, releasing all liens,…”
Work Zone Saf., Inc. v. Crest Hill Land Dev. LLC, 2015 IL App (1st) 140088 (Ill. App. Ct. 2015). · cites it 3× “For the first time, in its motion for preliminary injunction, CHLD identified section 12-183(b) of the Code of Civil Procedure (Code) (735 ILCS 5/12-183(b) (West 2012)) as the basis for its request for an order of satisfaction and release of lien.”
In Re Cnty. Treasurer, 813 N.E.2d 1101 (Ill. App. Ct. 2004). · cites it 2× “Rather, they all passed on section 12-183 of the Code (735 ILCS 5/12-183 (West 2002)), concerning the effect of the trial court's entry of a release and satisfaction of judgment offered by or compelled from the judgment creditor.”
First Am. Bank v. Poplar Creek, LLC, 2024 IL App (1st) 230551 (Ill. App. Ct. 2024). · cites it 2× “The remaining guarantors then sought a finding under section 12-183 of the Code 1-23-0551 of Civil Procedure (735 ILCS 5/12-183 (West 2022)) that the judgment had been satisfied when Poplar Creek assigned to First American as additional collateral a security interest in a tax…”
Andrews v. Norfolk S. R.R. Corp., 2017 IL App (1st) 153007 (Ill. App. Ct. 2017). “1-15-3007 183(b) of the Illinois Code of Civil Procedure (Code) (735 ILCS 5/12-183(b) (West 2006)). 3 Norfolk Southern asserted both a statutory and contractual right to setoff, claiming that in accepting the advances, plaintiff had agreed to repay Norfolk Southern from any…”
Work Zone Saf., Inc. v. Crest Hill Land Dev. LLC, 2015 IL App (1st) 140088 (Ill. App. Ct. 2015). “Instead, it relies solely on section 12-183 (735 ILCS 5/12-183(b) (West 2012)) as support for the circuit court’s award of equitable relief–a theory it first advanced in its motion for injunctive relief.”
Fed. Sign v. Fultz (In Re Fultz), 232 B.R. 709 (Bankr. N.D. Ill. 1999). “In Illinois, a satisfaction of judgment under 735 ILCS 5/12-183 merely serves as proof of payment of the judgment (which is normally filed of record to evidence such fact) and halts the accrual of post-judgment interest.”
Andrews v. Norfolk S. R.R. Corp., 2017 IL App (1st) 153007 (Ill. App. Ct. 2017). “2 ¶6 Norfolk Southern filed a posttrial motion seeking a setoff for its advances under section 55 of FELA and ultimately filed a petition to satisfy and release the judgment under section 12-183(b) of the Code of Civil Procedure (Code) (735 ILCS 5/12-183(b) (West 2006)).3…”
Potomac Consulting, In c v. IS Constr., Inc., 2024 IL App (1st) 221936-U (Ill. App. Ct. 2024). · cites it 4× “” The court noted that it has “jurisdiction to consider a set-off and satisfaction of judgment as a supplemental enforcement proceeding under Section 12-183(b)” (735 ILCS 5/12-183(b)) and that it therefore “properly construed and followed the law in ordering a set-off and…”
Tradex Global Fund SPC LTD. v. Solaris Opportunity Fund L.P., 2025 IL App (1st) 241104-U (Ill. App. Ct. 2025). · cites it 3× “3d 330, 336 (1996) (in a case of first impression, determining that the abuse of discretion was appropriate because a section 12-183(h) motion that argues an obligor has been released from judgment (735 ILCS 5/12-183(h) (West 1994)) is comparable to a section 2-1401 petition…”
Alexander v. Martinez, 2022 IL App (1st) 211369-U (Ill. App. Ct. 2022). · cites it 2× “1-21-1369 ¶ 23 Alexander filed her motion to release the 2017 judgment under section 12-183 of the Code (735 ILCS 5/12-183 (West 2018)). A proceeding under that section “determines whether all money due has been paid and the judgment has been satisfied.”
BMO Harris N.A. v. Sklarov, 2025 IL App (3d) 240704-U (Ill. App. Ct. 2025). · cites it 2× “5 ¶ 14 Next, defendant contends the petition to revive is barred by section 12-183(h) of the Code (735 ILCS 5/12-183(h) (West 2016)), 1 which states: “Upon the filing of a release or satisfaction in full satisfaction of judgment, signed by the party in whose favor the judgment…”
Show all 15 citing cases →
— 735 ILCS 5/12-183(a) — 2 cases
Alexander v. Martinez, 2022 IL App (1st) 211369-U (Ill. App. Ct. 2022). “1-21-1369 ¶ 23 Alexander filed her motion to release the 2017 judgment under section 12-183 of the Code (735 ILCS 5/12-183 (West 2018)). A proceeding under that section “determines whether all money due has been paid and the judgment has been satisfied.”
In re Support of M.S., 2020 IL App (1st) 182679-U (Ill. App. Ct. 2020).
— 735 ILCS 5/12-183(b) — 6 cases
Süd Fam. Ltd. P'ship v. Otto Baum Co., 2024 IL App (4th) 220782 (Ill. App. Ct. 2024). “The record shows Süd’s petition was filed pursuant to section 12-183(b) of the Code (735 ILCS 5/12-183(b) (West 2018)) and asked the trial court to enter an order (1) holding that the chancery judgments had been satisfied and (2) “releasing those judgments, releasing all liens,…”
Work Zone Saf., Inc. v. Crest Hill Land Dev. LLC, 2015 IL App (1st) 140088 (Ill. App. Ct. 2015). “For the first time, in its motion for preliminary injunction, CHLD identified section 12-183(b) of the Code of Civil Procedure (Code) (735 ILCS 5/12-183(b) (West 2012)) as the basis for its request for an order of satisfaction and release of lien.”
Andrews v. Norfolk S. R.R. Corp., 2017 IL App (1st) 153007 (Ill. App. Ct. 2017). “1-15-3007 183(b) of the Illinois Code of Civil Procedure (Code) (735 ILCS 5/12-183(b) (West 2006)). 3 Norfolk Southern asserted both a statutory and contractual right to setoff, claiming that in accepting the advances, plaintiff had agreed to repay Norfolk Southern from any…”
Work Zone Saf., Inc. v. Crest Hill Land Dev. LLC, 2015 IL App (1st) 140088 (Ill. App. Ct. 2015). “Instead, it relies solely on section 12-183 (735 ILCS 5/12-183(b) (West 2012)) as support for the circuit court’s award of equitable relief–a theory it first advanced in its motion for injunctive relief.”
Andrews v. Norfolk S. R.R. Corp., 2017 IL App (1st) 153007 (Ill. App. Ct. 2017). “2 ¶6 Norfolk Southern filed a posttrial motion seeking a setoff for its advances under section 55 of FELA and ultimately filed a petition to satisfy and release the judgment under section 12-183(b) of the Code of Civil Procedure (Code) (735 ILCS 5/12-183(b) (West 2006)).3…”
— 735 ILCS 5/12-183(h) — 5 cases
In Re Cnty. Treasurer, 813 N.E.2d 1101 (Ill. App. Ct. 2004). “Rather, they all passed on section 12-183 of the Code (735 ILCS 5/12-183 (West 2002)), concerning the effect of the trial court's entry of a release and satisfaction of judgment offered by or compelled from the judgment creditor.”
Tradex Global Fund SPC LTD. v. Solaris Opportunity Fund L.P., 2025 IL App (1st) 241104-U (Ill. App. Ct. 2025). “3d 330, 336 (1996) (in a case of first impression, determining that the abuse of discretion was appropriate because a section 12-183(h) motion that argues an obligor has been released from judgment (735 ILCS 5/12-183(h) (West 1994)) is comparable to a section 2-1401 petition…”
BMO Harris N.A. v. Sklarov, 2025 IL App (3d) 240704-U (Ill. App. Ct. 2025). “5 ¶ 14 Next, defendant contends the petition to revive is barred by section 12-183(h) of the Code (735 ILCS 5/12-183(h) (West 2016)), 1 which states: “Upon the filing of a release or satisfaction in full satisfaction of judgment, signed by the party in whose favor the judgment…”
Doctor's Assocs., Inc. v. Duree (Ill. App. Ct. 2001).
Bricks, Inc. v. C&F Developers, Inc. (Ill. App. Ct. 2005).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.