Maine Revised Statutes

Me. Rev. Stat. tit. 14, § 864 (2026)

Presumption of payment after 20 years

✓ current as of May 2026

Find cases: SyfertCases citing this section ME-LEGlegislature.maine.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

Every judgment and decree of any court of record of the United States or of any state or justice of the peace in this State is presumed to be paid and satisfied at the end of 20 years after any duty or obligations accrued by virtue of such judgment or decree, except for a child support order. For the purposes of this section, "child support order" means a judgment, decree or order, whether temporary, final or subject to modification, issued by a court or an administrative agency of competent jurisdiction for the support and maintenance of a child, including a child who has attained the age of majority under the law of the issuing state, that provides for monetary support, health care, arrearages or reimbursement and may include related costs and fees, interest and penalties, income withholding, attorney's fees and other relief. [PL 2017, c. 102, §1 (AMD).]

SECTION HISTORY

PL 2017, c. 102, §1 (AMD).

Notes of Decisions

Cited in 7 cases, 1992–2020 · leading case: Catherine E. Brochu v. Richard A. McLeod, 2016 ME 146 (Me. 2016).

Sort: Relevance Newest Treatment

Catherine E. Brochu v. Richard A. McLeod, 2016 ME 146 (Me. 2016). “14 M.R.S. § 864 (2015). 4 . See, e.g., In re Marriage of Boswell, 225 Cal.”

Carter v. Carter, 611 A.2d 86 (Me. 1992). “14 M.R.S.A. § 864 (1980) creates a presumption of payment of obligations accruing by virtue of judgments or decrees after the lapse of twenty years; this section does not, however, bar actions after that time.”

In Re Goodwin, 325 B.R. 328 (Bankr. M.D. Fla. 2005). “” 14 M.R.S.A. § 864. 4 . The Florida Supreme Court agrees with and expressly approves the Fifth District Court of Appeals opinion it affirms.”

Frances Quirk v. John E. Quirk Sr., 2020 ME 132 (Me. 2020). · cites it 2× “DISCUSSION [¶9] John asserts the following four arguments to attack the judgment: (A) his laches defense should have prevailed; (B) the trial court should not have awarded the full amount of post-judgment interest to Frances; (C) there was insufficient evidence to overcome the…”

Cloutier v. Turner, 34 A.3d 1146 (Me. 2012). “There is no statute of limitations for money judgments; rather, there is a statutory presumption of payment after the lapse of twenty years pursuant to 14 M.R.S. § 864 (2011). See Carter, 611 A.”

Frances Quirk v. John E. Quirk Sr., 2020 ME 132 (Me. 2020). · cites it 2× “DISCUSSION [¶9] John asserts the following four arguments to attack the judgment: (A) his laches defense should have prevailed; (B) the trial court should not have awarded the full amount of post-judgment interest to Frances; (C) there was insufficient evidence to overcome the…”

Faith Temple v. DiPietro (Me. Super. Ct 2016). · cites it 2× “To support his position the Defendant cites 14 M.R.S. § 864 which states that, Every judgment and decree of any court of record of the United States, or of any state, or justice of the peace in this State shall be presumed to be paid and satisfied at the end of 20 years after…”

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.