Indiana Code

Ind. Code § 34-11-2-12 (2026)

Satisfaction of judgment after expiration of 20 years

✓ current as of May 2026
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     Sec. 12. Every judgment and decree of any court of record of the United States, of Indiana, or of any other state shall be considered satisfied after the expiration of twenty (20) years.

[Pre-1998 Recodification Citation: 34-1-2-14.]

As added by P.L.1-1998, SEC.6.

 

Notes of Decisions
Cited in 16 cases (3 in the last 5 years), 2000–2024 · leading case: Lewis v. Rex Metal Craft, Inc., 831 N.E.2d 812 (Ind. Ct. App. 2005).
Lewis v. Rex Metal Craft, Inc., 831 N.E.2d 812 (Ind. Ct. App. 2005). · cites it 40× “2d at 1176 (referring to Ind.Code § 34-11-2-12 as a statute of limitations).”
Arend v. Etsler, 737 N.E.2d 1173 (Ind. Ct. App. 2000). · cites it 10× “Discussion and Decision Arend contends that the money judgment may be executed because the judgment does not violate the twenty year statute of limitations of Indiana Code section 34-11-2-12. A judgment creditor has several methods to choose from in collecting a final judgment…”
Skolak v. Skolak, 895 N.E.2d 1241 (Ind. Ct. App. 2008). · cites it 16× “The State next directs our attention to Indiana Code section 34-11-2-12, which states that "[e]very judgment and decree of any court of record of the United States, of Indiana, or of any other state shall be considered satisfied after the expiration of twenty (20) years." The…”
Bell v. Heflin, 383 P.3d 1031 (Wash. 2016). · cites it 3× “210(2) that states, “An action to enforce a child support obligation must be commenced not later than ten (10) years after: (1) the eighteenth birthday of the child; or (2) the emancipation of the child; whichever occurs first.” Ind. Code § 34-11-2-10 . But Indiana also has a…”
Katherine Ryan v. Larry Janovsky, 999 N.E.2d 895 (Ind. Ct. App. 2013). · cites it 6× “Janovsky cites to Indiana Code section 34-11-2-12 and to Needham v. Suess, 577 N.”
Dore v. Dore, 782 N.E.2d 1015 (Ind. Ct. App. 2003). · cites it 4× “See Ind.Code § 34-11-2-12, which provides that: Every judgment and decree of any court of record of the United States, of Indiana, or of any other state shall be considered satisfied after the expiration of twenty (20) years.”
Est. of Wilson v. Steward, 937 N.E.2d 826 (Ind. Ct. App. 2010). · cites it 12× “[3] Father's estate contends that Mother's claim is barred by Indiana Code Section 34-11-2-10, which governs the enforcement of child support obligations, and by Indiana Code Section 34-11-2-12, which governs the enforeement of money judgments.”
Burkett v. Am. Fam. Ins. Grp., 737 N.E.2d 447 (Ind. Ct. App. 2000). · cites it 2× “Ind.Code § 34-11-2-12 provides: "Every judgment and decree of any court of record of the United States, of Indiana, or of any other state shall be considered satisfied after the expiration of twenty (20) years.”
Freddie L. Webb v. Thomas A. Yeager, 52 N.E.3d 30 (Ind. Ct. App. 2016). · cites it 4× “See Ind.Code § 34-11-2-12 (titled “Satisfaction of judgment after expiration of twenty years” and providing that “[e]very judgment and decree of any court of record of the United States, of Indiana, or of any other state shall be considered satisfied after the expiration of…”
Est. of Moreland v. Dieter, 576 F.3d 691 (7th Cir. 2009). “Ind.Code § 34-11-2-12. Making the entities suddenly responsible for liability imposed during the first term of the Reagan Administration would neither preserve the treasury nor discourage excessive litigation.”
Off. of Child Support Enf't v. Reagan, 202 S.W.3d 10 (Ark. Ct. App. 2005). · cites it 3× “” OCSE argued that Indiana Code § 34-11-2-12 allowed judgments to be enforceable for twenty years.”
Barbara Chitwood v. John Guadagnoli (Ind. Ct. App. 2024). · cites it 4× “See Ind. Code § 34-11-2-12 (judgment is considered satisfied after twenty years).”
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.