Mich. Comp. Laws » Michigan Compiled Laws / Chapter 600 / Act 236 of 1961
Michigan Compiled Laws

Mich. Comp. Laws § 600.6104 (2026)

Powers of judge after rendition of judgment for money.

✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961


Act 236 of 1961


600.6104 Powers of judge after rendition of judgment for money.

Sec. 6104.

    After judgment for money has been rendered in an action in any court of this state, the judge may, on motion in that action or in a subsequent proceeding:

    (1) Compel a discovery of any property or things in action belonging to a judgment debtor, and of any property, money, or things in action due to him, or held in trust for him;

    (2) Prevent the transfer of any property, money, or things in action, or the payment or delivery thereof to the judgment debtor;

    (3) Order the satisfaction of the judgment out of property, money, or other things in action, liquidated or unliquidated, not exempt from execution;

    (4) Appoint a receiver of any property the judgment debtor has or may thereafter acquire; and

    (5) Make any order as within his discretion seems appropriate in regard to carrying out the full intent and purpose of these provisions to subject any nonexempt assets of any judgment debtor to the satisfaction of any judgment against the judgment debtor.

    The court may permit the proceedings under this chapter to be taken although execution may not issue and other proceedings may not be taken for the enforcement of the judgment. It is not necessary that execution be returned unsatisfied before proceedings under this chapter are commenced.

History: 1961, Act 236, Eff. Jan. 1, 1963 ;-- Am. 1974, Act 297, Eff. Apr. 1, 1975

Notes of Decisions
Cited in 48 cases (16 in the last 5 years), 1971–2026 · leading case: Edward Gallagher v. Kathleen Persha, 315 Mich. App. 647 (Mich. Ct. App. 2016).
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Edward Gallagher v. Kathleen Persha, 315 Mich. App. 647 (Mich. Ct. App. 2016). · cites it 6× “The circuit court granted the plaintiffs motion to pierce the corporate veil and hold Ziegelman liable for the previous judgment against NZA, citing MCL 600.6104 as author *656 ity for its entry of a judgment against Ziegelman individually.”
Arbor Farms, LLC v. Geostar Corp., 853 N.W.2d 421 (Mich. Ct. App. 2014). · cites it 5× “See MCL 600.6104. To the extent defendant contends no valid order existed because the trial court lacked personal jurisdiction, these jurisdictional contentions are without merit for the reasons already explained in this opinion.”
Green v. Ziegelman, 767 N.W.2d 660 (Mich. Ct. App. 2009). · cites it 4× “MCL 600.6104 provides that after money judgment has been rendered the judge may on motion in that action or in a subsequent action make any order as within their discretion whatever seems appropriate in regard to the carrying out the full intent and purpose and to subject any…”
Avant Capital Partners, LLC v. Strathmore Dev. Co. Michigan, 703 F. App'x 362 (6th Cir. 2017). · cites it 7× “Mich. Comp. Laws § 600.6104 (emphasis added).”
In Re John Richards Homes Bldg. Co., LLC, 298 B.R. 591 (Bankr. E.D. Mich. 2003). · cites it 3× “§ 600.6104(5), the Court concludes that with certain exceptions, JRH is entitled to the turnover order that it seeks, as well as an order requiring the Michigan Secretary of State to record liens in favor of JRH on vehicles still titled in Adell’s name.”
Ryan Racing, LLC v. Gentilozzi, 231 F. Supp. 3d 269 (W.D. Mich. 2017). · cites it 2× “However, this Court distinguished Green I because Plaintiff asserted new claims against Gentilozzi in Counts 1 and 2 (fraudulent transfer and conspiracy to commit fraudulent conveyance) that were not required to have been brought in the state-court action.”
Abel v. Grossman Investments Co., 838 N.W.2d 204 (Mich. Ct. App. 2013). “2926; MCL 600.6104(4) (governing court appointment of receivers).”
Shouneyia v. Shouneyia, 807 N.W.2d 48 (Mich. Ct. App. 2011). “” MCL 600.6104(4). [MCL 600.2926] has been interpreted as authorizing a circuit court to appoint a receiver when specifically allowed by statute and also when no specific statute applies but the facts and circumstances render the appointment of a receiver an appropriate exercise…”
In Re Goehring, 457 N.W.2d 375 (Mich. Ct. App. 1990). “Pursuant to MCL 600.6104 and 600.6110; MSA 27A.6104 and 27A.”
Hofmeister v. Randall, 335 N.W.2d 65 (Mich. Ct. App. 1983). “Defendant Ronald Aldrich appeals as of right an order issued February 26, 1982, appointing a receiver, pursuant to MCL 600.6104; MSA 27A.6104, and requiring him to turn over to the receiver all of his real and personal property.”
TTOD Liquidation, Inc. v. Lim (In re DOTT Acquisition, LLC), 520 B.R. 588 (Bankr. E.D. Mich. 2014). · cites it 2× “At TTOD’s request, on June 23, 2010 and June 24, 2010, the Circuit Court entered separate orders (“Post-Judgment Orders”) enjoining Dott Acquisition and Gruits from transferring any of the assets of Dott Acquisition and explaining that both orders were “issued pursuant to MCL…”
Cates v. Moyses, 226 N.W.2d 106 (Mich. Ct. App. 1975). “*407 On September 12, 1972, a hearing was had on plaintiffs’ petition for discovery of assets under MCLA 600.6104; MSA 27A.6104. On September 20, 1972, after the first hearing on the above mentioned motion, the company paid into court the sum of $10,330.”
Show all 48 citing cases →
— Mich. Comp. Laws § 600.6104(1) — 3 cases
Arbor Farms, LLC v. Geostar Corp., 853 N.W.2d 421 (Mich. Ct. App. 2014). “See MCL 600.6104. To the extent defendant contends no valid order existed because the trial court lacked personal jurisdiction, these jurisdictional contentions are without merit for the reasons already explained in this opinion.”
in Re Coats Est. (Mich. Ct. App. 2017).
in Re Coats Est. (Mich. Ct. App. 2017).
— Mich. Comp. Laws § 600.6104(2) — 3 cases
Motley v. Metro Man I, Inc. (E.D. Mich. 2023).
Motley v. Metro Man I, Inc. (E.D. Mich. 2023).
Motley v. Metro Man I, Inc. (E.D. Mich. 2023).
— Mich. Comp. Laws § 600.6104(3) — 6 cases
Cunningham Davison Beeby Rogers & Alward v. Herr, 497 N.W.2d 575 (Mich. Ct. App. 1993).
in Re Coats Est. (Mich. Ct. App. 2017).
in Re Coats Est. (Mich. Ct. App. 2017).
Dc Mex Holdings LLC v. Affordable Land LLC (Mich. Ct. App. 2017).
Dc Mex Holdings LLC v. Affordable Land LLC (Mich. Ct. App. 2017).
— Mich. Comp. Laws § 600.6104(4) — 6 cases
Arbor Farms, LLC v. Geostar Corp., 853 N.W.2d 421 (Mich. Ct. App. 2014). “See MCL 600.6104. To the extent defendant contends no valid order existed because the trial court lacked personal jurisdiction, these jurisdictional contentions are without merit for the reasons already explained in this opinion.”
Abel v. Grossman Investments Co., 838 N.W.2d 204 (Mich. Ct. App. 2013). “2926; MCL 600.6104(4) (governing court appointment of receivers).”
Shouneyia v. Shouneyia, 807 N.W.2d 48 (Mich. Ct. App. 2011). “” MCL 600.6104(4). [MCL 600.2926] has been interpreted as authorizing a circuit court to appoint a receiver when specifically allowed by statute and also when no specific statute applies but the facts and circumstances render the appointment of a receiver an appropriate exercise…”
Motley v. Metro Man I, Inc. (E.D. Mich. 2023).
Motley v. Metro Man I, Inc. (E.D. Mich. 2023).
— Mich. Comp. Laws § 600.6104(5) — 7 cases
Edward Gallagher v. Kathleen Persha, 315 Mich. App. 647 (Mich. Ct. App. 2016). “The circuit court granted the plaintiffs motion to pierce the corporate veil and hold Ziegelman liable for the previous judgment against NZA, citing MCL 600.6104 as author *656 ity for its entry of a judgment against Ziegelman individually.”
In Re John Richards Homes Bldg. Co., LLC, 298 B.R. 591 (Bankr. E.D. Mich. 2003). “§ 600.6104(5), the Court concludes that with certain exceptions, JRH is entitled to the turnover order that it seeks, as well as an order requiring the Michigan Secretary of State to record liens in favor of JRH on vehicles still titled in Adell’s name.”
Green v. Ziegelman, 767 N.W.2d 660 (Mich. Ct. App. 2009). “MCL 600.6104 provides that after money judgment has been rendered the judge may on motion in that action or in a subsequent action make any order as within their discretion whatever seems appropriate in regard to the carrying out the full intent and purpose and to subject any…”
Avant Capital Partners, LLC v. Strathmore Dev. Co. Michigan, 703 F. App'x 362 (6th Cir. 2017). “Mich. Comp. Laws § 600.6104 (emphasis added).”
Hartford Underwriters Ins. Co. v. Omega Resources Solutions, LLC (E.D. Mich. 2021).
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