Minnesota Statutes

Minn. Stat. § 541.04 (2026)

Judgments, Ten Years

✓ current as of May 2026
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No action shall be maintained upon a judgment or decree of a court of the United States, or of any state or territory thereof, unless begun within ten years after the entry of such judgment.

Notes of Decisions
Cited in 22 cases (1 in the last 5 years), 1983–2022 · leading case: Dahlin v. Kroening, 796 N.W.2d 503 (Minn. 2011).
Dahlin v. Kroening, 796 N.W.2d 503 (Minn. 2011). · cites it 30× “The issue presented in this case is whether a judgment creditor, by bringing an action on a previously renewed judgment, may renew the judgment for an additional ten years pursuant to Minn.Stat. § 541.04 (2010). The district court concluded that section 541.”
All Finish Concrete, Inc. v. Erickson, 899 N.W.2d 557 (Minn. Ct. App. 2017). · cites it 24× “” Minn. Stat. § 541.04 . Here, All Finish obtained a judgment against Erickson Contracting in May 2012.”
Amica Mut. Ins. Co. v. Wartman, 841 N.W.2d 637 (Minn. Ct. App. 2014). · cites it 32× “Wartman dismissing appellant’s suit claiming entitlement to “piercing of the corporate veil” because the underlying judgment against the corporate entity had expired under Minn.Stat. § 541.04. We affirm. FACTS Respondent was the owner and sole shareholder of Landform, Inc.”
Dahlin v. Kroening, 784 N.W.2d 406 (Minn. Ct. App. 2010). · cites it 12× “See Minn.Stat. § 541.04 (2008). Kroening did not pay, so Dahlin sued him within ten years in 1988 for failure to pay, and the district court entered a new judgment for $7,000 in Dahlin's favor in April 1988.”
Matson v. Matson, 333 N.W.2d 862 (Minn. 1983). · cites it 6× “Appellant next contends that Minn. Stat. §§ 541.04 and 550.01 (1982), the Minnesota 10-year limitation of actions statutes, preclude enforcement of the 1980 Wisconsin judgment to the extent that that judgment includes support and alimony accruing more than 10 years before…”
Marriage of Gerber v. Gerber, 714 N.W.2d 702 (Minn. 2006). · cites it 11× “This case presents the narrow issue of whether the 10-year statute of limitations for an “action” brought on a judgment, Minn.Stat. § 541.04 (2004), applies to a county’s administrative attempt to satisfy a child support obligor’s arrearages through income withholding collection…”
Shamrock Dev., Inc. v. Smith, 754 N.W.2d 377 (Minn. 2008). · cites it 2× “Minn. Stat. § 541.04 (2006). Judgment creditors sometimes seek to renew an existing judgment by commencing a new civil action within the 10-year limitations period and obtain a new judgment.”
Bednarek v. Bednarek, 430 N.W.2d 9 (Minn. Ct. App. 1988). · cites it 9× “The statute of limitations in question, Minn.Stat. § 541.04, bars actions for child support arrearages that are more than ten years old.”
In Re Sitarz, 150 B.R. 710 (Bankr. D. Minn. 1993). · cites it 2× “Under Minnesota law, a civil judgment survives, and the statutory lien securing it is enforceable, for a period of ten years after the docketing of the judgment.”
Jensen v. Fhima, 731 N.W.2d 876 (Minn. Ct. App. 2007). · cites it 5× “The affidavit provided that appellant intended to bring a motion to vacate the judgment on the ground that the judgment was no longer enforceable pursuant to Minn.Stat. § 541.04 (2006) and Cal.Civ.Proc.”
Shamrock Dev., Inc. v. Smith, 737 N.W.2d 372 (Minn. Ct. App. 2007). · cites it 2× “” Minn. Stat. § 541.04 (2006). The procedure for renewing a judgment is not specifically prescribed by statute, but caselaw indicates that actions are routinely brought to renew judgments so that the judgments extend beyond the initial ten-year period.”
Marriage of Nazarenko v. Mader, 362 N.W.2d 1 (Minn. Ct. App. 1985). · cites it 4× “By order dated May 21, 1984, a family court referee ordered that appellant’s motion to award judgment was denied based on the statute of limitations contained in Minn.Stat. §§ 541.04, 550.01, 548.09, subd.”
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