Massachusetts General Laws

Mass. Gen. Laws ch. 260, § 20 (2026)

Presumption of satisfaction of judgment

✓ current as of July 2026

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Section 20. A judgment or decree of a court of record of the United States or of any state thereof shall be presumed to be paid and satisfied at the expiration of twenty years after it was rendered.

Notes of Decisions

Cited in 25 cases (1 in the last 5 years), 1994–2024 · leading case: Milliken & Co. v. Duro Textiles, LLC, 887 N.E.2d 244 (Mass. 2008).

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Milliken & Co. v. Duro Textiles, LLC, 887 N.E.2d 244 (Mass. 2008). “See G. L. c. 260, § 20. Mil-liken did not lose the right to recover the trade debt owed by Old Duro simply because its corporate successor, New Duro, had insufficient assets in October, 2002, to repay the debt.”

Lombardi v. Lombardi, 862 N.E.2d 436 (Mass. App. Ct. 2007). · cites it 2× “See G. L. c. 260, § 20, providing that “[a] judgment or decree of a court of record of the United States or of any state thereof shall be presumed to be paid and satisfied at the expiration of twenty years after it was rendered.”

Aa & D Masonry, LLC v. S. St. Bus. Park, LLC, 107 N.E.3d 1229 (Mass. App. Ct. 2018). · cites it 2× “That statute provides, in relevant part, that if a judgment remains unsatisfied, the judgment creditor "may at any time after the judgment, subject to [G. L. c. 260, § 20, providing that a judgment is presumed satisfied twenty years after it is rendered], bring a civil action…”

Cavadi v. DeYeso, 941 N.E.2d 23 (Mass. 2011). “G. L. c. 260, § 20. 6 Bames testified at trial and the judge did not believe his testimony.”

Child Support Enf't Div. of Alaska v. Brenckle, 675 N.E.2d 390 (Mass. 1997). “G. L. c. 260, § 20. However calculated, these proceedings were commenced within the applicable time period.”

United States v. Rostoff, 164 F.3d 63 (1st Cir. 1999). “See Mass. Gen. Laws ch. 260, § 20 . If the Rostoffs’ reading were correct, and the restitution order was limited by the probationary period, it would render both these provisions of subsection (h) nugatory.”

Billingham v. Simpson (In Re Simpson), 334 B.R. 298 (Bankr. D. Mass. 2005). · cites it 2× “The Trustee contends that, because he is relying on the standing of a judgment creditor, the limitations period is the twenty-year period made applicable to enforcement of judgments in Massachusetts by G.L. c. 260, § 20. The Court agrees with the Trustee that, if the UFCA…”

Langone v. Esernia, 847 F. Supp. 214 (D. Mass. 1994). “See Mass.Gen.L. ch. 260, § 20 (1992) (“A judgment or decree of a court of record of the United States or of any court thereof shall be presumed to be paid and satisfied at the expiration of twenty years after it was rendered.”

De Prins v. Michaeles, 942 F.3d 521 (1st Cir. 2019). “"There are many reasons why a party may choose not to raise an issue, or to contest an assertion, in a particular 1 Michaeles also argues that the district court was wrong to hold that the twenty-year period found in Mass. Gen. Laws ch. 260, § 20 was the applicable statute of…”

Mashpee Wampanoag Rod & Gun Club v. Garvey, 1999 Mass. App. Div. 224 (Mass. Dist. Ct., App. Div. 1999). “260, section 20 collectible for 20 years and M.G.L.c. 260, section 20 which makes judgments valid for 20 years.”

De Prins v. Michaeles, 342 F. Supp. 3d 199 (2018). · cites it 2× “Plaintiff argues that his Complaint is not time barred because his claim of reach and apply would be held to the statute of limitations set forth in Mass. Gen. L. c. 260 § 20, allowing 20 years.”

Meaney v. OneBeacon Ins., 27 Mass. L. Rptr. 10 (Mass. Super. Ct. 2010). “251, §§11, 14, and therefore that G.L.c. 260, §20, which allows a twenty-year statute of limitations on claims to enforce a judgment, applies.”

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