Mont. Code Ann. » TITLE 27. CIVIL LIABILITY, REMEDIES, AND LIMITATIONS · CHAPTER 2. STATUTES OF LIMITATIONS · Part 2. Time Limits on Specific Kinds of Actions
Montana Code Annotated

Mont. Code Ann. § 27-2-201 (2026)

Actions Upon Judgments

✓ current as of May 2026
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  1. MCA Contents
  2. TITLE 27
  3. CHAPTER 2
  4. Part 2
  5. 27-2-201 Actions upon judgments

TITLE 27. CIVIL LIABILITY, REMEDIES, AND LIMITATIONS

CHAPTER 2. STATUTES OF LIMITATIONS

Part 2. Time Limits on Specific Kinds of Actions

Actions Upon Judgments

27-2-201. Actions upon judgments. (1) Except as provided in subsections (3) through (5), the period prescribed for the commencement of an action upon a judgment or decree of any court of record of the United States or of any state within the United States is within 10 years.

(2) The period prescribed for the commencement of an action upon a judgment or decree rendered in a court not of record is within 10 years. The cause of action is considered, in that case, to have accrued when final judgment was rendered.

(3) The period prescribed for the commencement of an action to collect past-due child support that has accrued after October 1, 1993, under an order entered by a court of record or administrative authority is within 10 years of the termination of support obligation or within 10 years from entry of a lump-sum judgment or order for support arrears, whichever is later.

(4) The period prescribed for the commencement of an action to collect past-due child support that has accrued under a support order issued in another state, in a foreign country, or in a tribal court is as provided in subsection (3) or as provided in the law of the issuing jurisdiction, whichever period is longer.

(5) An action under 46-18-247(3) to enforce an order of restitution entered by a court of record may be commenced at any time within the offender's lifetime during which restitution remains unpaid.

History: Ap. p. Sec. 1, p. 172, L. 1889; amd. Sec. 511, C. Civ. Proc. 1895; re-en. Sec. 6444, Rev. C. 1907; re-en. Sec. 9028; R.C.M. 1921; Cal. C. Civ. Proc. Sec. 336; re-en. Sec. 9028, R.C.M. 1935; Sec. 93-2602, R.C.M. 1947; Ap. p. Sec. 513, C. Civ. Proc. 1895; amd. Sec. 1, Ch. 157, L. 1901; amd. Sec. 1, Ch. 128, L. 1903; re-en. Sec. 6446, Rev. C. 1907; re-en. Sec. 9030, R.C.M. 1921; Cal. C. Civ. Proc. Sec. 339; re-en. Sec. 9030, R.C.M. 1935; amd. Sec. 13, Ch. 263, L. 1975; Sec. 93-2604, R.C.M. 1947; Ap. p. Sec. 510, C. Civ. Proc. 1895; re-en. Sec. 6443, Rev. C. 1907; re-en. Sec. 9027, R.C.M. 1921; Cal. C. Civ. Proc. Sec. 335; re-en. Sec. 9027, R.C.M. 1935; Sec. 93-2601, R.C.M. 1947; R.C.M. 1947, 93-2601(part), 93-2602(1), 93-2604(2); amd. Sec. 5, Ch. 631, L. 1993; amd. Sec. 5, Ch. 60, L. 1995; amd. Sec. 39, Ch. 125, L. 1995; amd. Sec. 8, Ch. 264, L. 1995; amd. Sec. 1, Ch. 101, L. 1999; amd. Sec. 13, Ch. 515, L. 2001.

Notes of Decisions
Cited in 30 cases (4 in the last 5 years), 1984–2024 · leading case: Support Obligation of Day v. State, 900 P.2d 296 (Mont. 1995).
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Support Obligation of Day v. State, 900 P.2d 296 (Mont. 1995). · cites it 11× “Section 27-2-201(3), MCA (1993). (Emphasis added.) Since the child support arrearages in the instant case accrued prior to October 1, 1993, this statute cannot apply to the case before us on appeal.”
Robinson v. First Wyoming Bank, NA, 909 P.2d 689 (Mont. 1995). · cites it 12× “Specifically, § 27-2-201, MCA, did (and still does) permit actions on judgments of federal and state courts of record to be commenced in Montana within 10 years from the date of entry of the judgment.”
Jones v. Arnold, 900 P.2d 917 (Mont. 1995). · cites it 17× “We will discuss these various legal principles in the context of the facts of this case and the District Court’s decision. To summarize the following discussion, Montana law provides in separate statutes that a judgment may be enforced for a period of 10 years from docketing, §…”
In Re the Marriage of Brown, 867 P.2d 381 (Mont. 1994). · cites it 9× “Were Jody’s claims for child support obligations accruing more than ten years before the filing date of her Motion for Enforcement of the Divorce Decree and Order to Show Cause time-barred by § 27-2-201, MCA? 3. Did the District Court err when it computed Stephen’s past and…”
Bekkedahl v. McKittrick, 2002 MT 250 (Mont. 2002). · cites it 3× “Section 27-2-201, MCA. ¶18 Appellants also argue that, in the alternative, the statute of limitations did not begin to run until they were removed as McKittrick’s attorneys.”
Fulton v. Fulton, 2004 MT 240 (Mont. 2004). · cites it 18× “We see no reason to treat maintenance payments differently in this instance than we treated child support under the 1991 version of § 27-2-201, MCA. ¶14 In conclusion, we hold that when a judgment award requires monthly payments, for purposes of applying the statute of…”
Welch v. Huber, 862 P.2d 1180 (Mont. 1993). · cites it 7× “The dispositive issue is whether the judgment in this case is barred because the judgment creditor did not file an action to extend the judgment within ten years of the date the judgment was entered, as permitted by § 27-2-201(1), MCA. During 1980, Lorn Welch (Lorn) loaned money…”
In Re the Marriage of Weber, 2004 MT 206 (Mont. 2004). · cites it 4× “ISSUE THREE ¶24 Whether the motion to enforce was time barred. ¶25 Mark contends that Gail’s motion to enforce was stale because Gail did not bring the motion to enforce until eleven years after the decree and because under § 27-2-201, MCA, actions on judgments and decrees must…”
Momsen v. Momsen, 2006 MT 233 (Mont. 2006). · cites it 6× “” ¶15 We disagree and hold that the ten-year statute of limitations established in § 27-2-201, MCA, bars Jean’s claim for premarital child support.”
Willoughby v. Loomis, 869 P.2d 271 (Mont. 1994). · cites it 6× “Section 27-2-201(1), MCA. We have specifically determined that this ten-year statute of limitations applies to actions by one parent against another for child support arrearage.”
Helena Aerie No. 16 v. Montana Dep't of Revenue, 822 P.2d 1057 (Mont. 1991). · cites it 6× “Section 27-2-201(1), MCA. For the majority to grant a declaratory judgment on an issue that is at least 16, and perhaps 41, years old is alarming.”
Blomdahl v. Blomdahl, 2011 ND 78 (N.D. 2011). · cites it 2× “at 698; compare Mont. Code Ann. § 27-2-201 (1) (providing that the period prescribed for the commencement of an action upon a judgment or decree is within ten years) with N.”
Show all 30 citing cases →
— Mont. Code Ann. § 27-2-201(1) — 17 cases
Jones v. Arnold, 900 P.2d 917 (Mont. 1995). “We will discuss these various legal principles in the context of the facts of this case and the District Court’s decision. To summarize the following discussion, Montana law provides in separate statutes that a judgment may be enforced for a period of 10 years from docketing, §…”
Robinson v. First Wyoming Bank, NA, 909 P.2d 689 (Mont. 1995). “Specifically, § 27-2-201, MCA, did (and still does) permit actions on judgments of federal and state courts of record to be commenced in Montana within 10 years from the date of entry of the judgment.”
Welch v. Huber, 862 P.2d 1180 (Mont. 1993). “The dispositive issue is whether the judgment in this case is barred because the judgment creditor did not file an action to extend the judgment within ten years of the date the judgment was entered, as permitted by § 27-2-201(1), MCA. During 1980, Lorn Welch (Lorn) loaned money…”
Support Obligation of Day v. State, 900 P.2d 296 (Mont. 1995). “Section 27-2-201(3), MCA (1993). (Emphasis added.) Since the child support arrearages in the instant case accrued prior to October 1, 1993, this statute cannot apply to the case before us on appeal.”
Willoughby v. Loomis, 869 P.2d 271 (Mont. 1994). “Section 27-2-201(1), MCA. We have specifically determined that this ten-year statute of limitations applies to actions by one parent against another for child support arrearage.”
— Mont. Code Ann. § 27-2-201(2) — 1 case
Sw. Mont. Bldg. Indus. Ass'n v. City of Bozeman, 2018 MT 62 (Mont. 2018).
— Mont. Code Ann. § 27-2-201(3) — 6 cases
Support Obligation of Day v. State, 900 P.2d 296 (Mont. 1995). “Section 27-2-201(3), MCA (1993). (Emphasis added.) Since the child support arrearages in the instant case accrued prior to October 1, 1993, this statute cannot apply to the case before us on appeal.”
In Re the Marriage of Hopper, 1999 MT 310 (Mont. 1999).
Emery v. State Dept. of Pub. Health, 950 P.2d 764 (Mont. 1997).
Fulton v. Fulton, 2004 MT 240 (Mont. 2004). “We see no reason to treat maintenance payments differently in this instance than we treated child support under the 1991 version of § 27-2-201, MCA. ¶14 In conclusion, we hold that when a judgment award requires monthly payments, for purposes of applying the statute of…”
T. Boudette v. D. Boudette, 2024 MT 131N (Mont. 2024).
— Mont. Code Ann. § 27-2-201(4) — 1 case
T. Boudette v. D. Boudette, 2024 MT 131N (Mont. 2024).
— Mont. Code Ann. § 27-2-201(l) — 2 cases
Jones v. Arnold, 900 P.2d 917 (Mont. 1995). “We will discuss these various legal principles in the context of the facts of this case and the District Court’s decision. To summarize the following discussion, Montana law provides in separate statutes that a judgment may be enforced for a period of 10 years from docketing, §…”
Support Obligation of Day v. State (Mont. 1995).
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.