Michigan Compiled Laws

Mich. Comp. Laws § 600.2819 (2026)

Foreclosure.

✓ current as of July 2026

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REVISED JUDICATURE ACT OF 1961

Act 236 of 1961

600.2819 Foreclosure.

Sec. 2819.

There is no right to foreclose a judgment lien created under this chapter. At the time the judgment debtor makes a conveyance, as that term is defined in section 35 of 1846 RS 65, MCL 565.35, of, sells under an executory contract, or refinances the interest in real property that is subject to the judgment lien, the judgment debtor shall pay the amount due to the judgment creditor, as determined under section 2807(3), to the judgment creditor.

History: Add. 2004, Act 136, Eff. Sept. 1, 2004

Notes of Decisions

Cited in 8 cases (2 in the last 5 years), 2006–2023 · leading case: Thomas v. Dutkavich, 803 N.W.2d 352 (Mich. Ct. App. 2010).

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Thomas v. Dutkavich, 803 N.W.2d 352 (Mich. Ct. App. 2010). · cites it 16× “Plaintiff further alleged, as part of count I, that he owned the property free and clear of the Dutkaviches’ interest and that, under MCL 600.2819, there could be no foreclosure on the lien and Thomas could not be held liable to the Dutkaviches.”

Ypsilanti Charter Twp. v. Kircher, 761 N.W.2d 761 (Mich. Ct. App. 2008). · cites it 2× “2801 through MCL 600.2819. Defendant erroneously cites authority from the judgment foreclosure statutes in the Revised Judicature Act.”

In Re Guzior, 347 B.R. 237 (Bankr. E.D. Mich. 2006). “2807 (1) was somehow relevant to the issue before the Court, the Debtor is precluded from relying on it.”

Larson Real Est. Ventures LLC v. Abbott Park Inc (Mich. Ct. App. 2023). · cites it 7× “Specifically, the supplemental complaint alleges that Larson was entitled to payment of the funds under MCL 600.2819 and MCL 600.2807 and that Nations failed to pay the funds to Larson, thereby depriving Larson of its interest in the funds.”

Weatherseal Home Improvements Inc v. Richard J Sable (Mich. Ct. App. 2014). · cites it 2× “Plaintiff specifically cites MCL 600.2819, which states: There is no right to foreclose a judgment lien created under this chapter.”

Harris v. Malone (E.D. Mich. 2021). “criminal claims in a civil action; (4) Plaintiffs fail to state an equal protection claim; (5) Plaintiffs fail to identify a municipal policy that caused a constitutional violation; (6) Defendants are entitled to qualified immunity; (7) Plaintiffs’ claims are barred by…”

Janice M Dollen v. Jack D Dollen (Mich. Ct. App. 2014). “Second, defendant argues that the trial court erred by denying his motion to quash garnishment because the payment could only be secured by a judicial lien and garnishment was not applicable to divorce judgments.”

Kevin Rankin v. City of Highland Park (Mich. Ct. App. 2015). “2819 Plaintiff also alleged in his complaint that defendants did not include him in the eviction proceedings and thus unlawfully interfered with his possessory interests in the property in violation of MCL 600.2918.5 It is plaintiff’s position that he obtained a possessory…”

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