Ohio Rev. Code » Chapter 2329
Ohio Revised Code

Ohio Rev. Code § 2329.07 (2026)

Judgment may become dormant

✓ current as of May 2026
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Effective:
April 6, 2017
Latest Legislation:
Senate Bill 227 - 131st General Assembly
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(A) As used in this section:

"Aid of execution" means an aid of execution under Chapter 2333. of the Revised Code, including the issuance of an order to a judgment debtor to appear for examination under section 2333.10 of the Revised Code.

"Certificate of judgment" means a certificate issued by a clerk of courts in which the judgment was rendered, under the seal of the court, under section 2329.02 or 2329.04 of the Revised Code.

"Execution" has the meaning defined in section 2327.01 of the Revised Code.

"Garnishment" means a proceeding commenced when an order of garnishment of personal earnings or an order of garnishment of property other than personal earnings is issued by a court.

For purposes of this section, an order of garnishment of personal earnings is continuing when regular garnishment payments are being made in accordance with a judgment debtor's regular pay schedule. An order of garnishment other than personal earnings is continuing until the garnishee files an answer.

"Renewal of the judgment" means the occurrence of any of the actions set forth under division (B) or (C) of this section.

(B)(1) A judgment that is not in favor of the state is dormant and shall not operate as a lien against the estate of the judgment debtor unless one of the following occurs within five years from the date of the judgment or any renewal of the judgment, whichever is later:

(a) An execution on a judgment is issued.

(b) A certificate of judgment for obtaining a lien upon lands and tenements is issued and filed, as provided in sections 2329.02 and 2329.04 of the Revised Code.

(c) An order of garnishment is issued or is continuing, or until the last garnishment payment is received by the clerk of courts or the final report is filed by the garnishee, whichever is later.

(d) A proceeding in aid of execution is commenced or is continuing.

(2) Except as otherwise provided in division (D) of this section, a judgment in favor of the state, is dormant and shall not operate as a lien against the estate of the judgment debtor unless one of the following occurs within ten years from the date of the judgment, or any renewal of the judgment, or within fifteen years from the date of the issuance of the last execution thereon, whichever is later:

(a) An execution on the judgment is issued.

(b) A certificate of judgment is issued and filed, as provided in sections 2329.02 and 2329.04 of the Revised Code.

(c) An order of garnishment is issued or is continuing, or until the last garnishment payment is received by the clerk of courts or the final report and answer is filed by the garnishee, whichever is later.

(d) A proceeding in aid of execution is commenced or is continuing.

The fifteen-year limitation period applies to executions issued and certificates of judgments issued and filed before, on, or after March 29, 2007.

(C) If, in any county other than that in which a judgment was rendered, the judgment has become a lien by reason of the filing, in the office of the clerk of the court of common pleas of that county, of a certificate of the judgment as provided in sections 2329.02 and 2329.04 of the Revised Code, or there has been a renewal of the judgment, except as otherwise provided under division (D) of this section, the judgment shall cease to operate as a lien upon lands and tenements of the judgment debtor within that county, unless one of the following occurs within five years or, if the judgment is in favor of the state, within fifteen years:

(1) An execution on a judgment is issued.

(2) A certificate of the judgment is filed in that county.

(3) An order of garnishment is issued or is continuing, or until the last garnishment payment is received by the clerk of courts or the final report and answer is filed by the garnishee, whichever is later.

(4) A proceeding in aid of execution is commenced or is continuing.

The fifteen-year limitation period applies to executions issued and certificates of judgments issued and filed before, on, or after March 29, 2007.

(D)(1) As used in division (D) of this section, "interim period" means the period beginning September 26, 2003, and ending September 27, 2006.

(2) Division (D) of this section applies only to judgments in favor of the state that are subject to this section and to which both of the following apply:

(a) The first issuance of execution on the judgment, or a garnishment or an aid in execution proceeding was commenced or continuing, or the certificate of judgment was filed within the ten-year period provided in this section before the beginning of the interim period;

(b) Subsequent issuance of execution on the judgment, or an order of garnishment or an aid in execution proceeding was commenced or continuing, or subsequent issuance and filing of the certificate of judgment would have been required during the interim period in order to keep the lien from becoming dormant under this section as this section existed on September 25, 2003, and as if this section as it existed on that date had been in effect during the interim period.

(3) Such a judgment shall become dormant and shall cease to operate as a lien against the estate of the judgment debtor unless one of the following occurs within fifteen years after the expiration of the ten-year period following issuance of the last execution on the judgment or following the issuance and filing of the last such certificate, whichever is later:

(a) An execution on the judgment is issued.

(b) A certificate of judgment is filed.

(c) A garnishment proceeding has been commenced or is continuing or until the last garnishment payment is received by the clerk of courts or the final report and answer is filed by the garnishee, whichever is later.

(d) A proceeding in aid of execution is commenced or is continuing.
Notes of Decisions
Cited in 41 cases (13 in the last 5 years), 1957–2026 · leading case: In Re Est. of Dinsio, 823 N.E.2d 43 (Ohio Ct. App. 2004).
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In Re Est. of Dinsio, 823 N.E.2d 43 (Ohio Ct. App. 2004). · cites it 11× “He contends that if a judgment creditor fails to take action on the judgment for five years from the date of issuance, the judgment becomes dormant, meaning no action to enforce the judgment may be taken by the judgment creditor, citing R.C. 2329.07. Therefore, appellant…”
Martin v. Stoddard (In Re Stoddard), 248 B.R. 111 (Bankr. N.D. Ohio 2000). · cites it 6× “O.R.C. § 2329.07. 1 Thereafter, upon becoming *117 dormant, the judgment may not be enforced, and is thus without legal effect, unless the judgment is revived in accordance with O.”
Columbus Check Cashers, Inc. v. Cary, 962 N.E.2d 812 (Ohio Ct. App. 2011). · cites it 4× “25 governs the procedure for the former type of revivor, 1 whereas R.C. 2329.07, 2325.15, and 2325.17 govern the procedure for the latter type of revivor.”
In re Est. of Mason, 849 N.E.2d 998 (Ohio 2006). · cites it 3× “Lump-Sum Judgments for Spousal Support Arrearages {¶ 15} Ohio’s dormancy statute, R.C. 2329.07, provides that “[i]f neither execution on a judgment rendered in a court of record or certified to the clerk of the court of common pleas in the county in which the judgment was…”
Myers v. Myers, 147 Ohio App. 3d 85 (Ohio Ct. App. 2002). · cites it 3× “” {¶ 33} In his final assignment of error, the appellant asserts that the 1970 judgment entry was dormant pursuant to the mandates of R.C. 2329.07, and, therefore, there was no longer an original existing judgment upon which to make an award of arrearage for future execution.”
Young v. Locke, 2014 Ohio 2500 (Ohio Ct. App. 2014). · cites it 2× “{¶ 6} Thereafter, the trial court vacated the order authorizing the judgment- debtor examination because, pursuant to R.C. 2329.07, a creditor cannot execute on a dormant judgment until the judgment has been revived.”
Discover Bank v. Wells, 2018 Ohio 4637 (Ohio Ct. App. 2018). · cites it 3× “07, the dormant judgment statute, provides in pertinent part: (B)(1) A judgment that is not in favor of the state is dormant and shall not operate as a lien against the estate of the judgment debtor unless one of the following occurs within five years from the date of the…”
In re Gretchen, 184 B.R. 284 (Bankr. S.D. Ohio 1995). · cites it 8× “07 of the Ohio Revised Code governs the dormancy of a judgment and validity of a judgment lien, and provides in relevant part as follows: If neither execution on a judgment rendered in a court of record or certified to the clerk of the court of common pleas in the county in…”
State v. Moore, 2021 Ohio 1616 (Ohio Ct. App. 2021). · cites it 3× “Appellant opposed the motions arguing that revivor of the dormant judgments was barred by the statute of limitations under R.C. 2329.07 and 2325.18(A). {¶ 5} On July 20, 2020, the trial court granted each of the state’s motions in separate judgment entries.”
Tabbaa v. Lexpro, L.L.C., 2020 Ohio 5514 (Ohio Ct. App. 2020). · cites it 2× “R.C. 2329.07(B) (a judgment becomes dormant unless a proceeding in aid of execution is commenced or ongoing); 62 Ohio Jurisprudence 3d, Judgments, Section 137 (providing an example that a judgment entered in another state was not dormant when the judgment creditor filed a…”
In Re Jaber, 406 B.R. 756 (Bankr. N.D. Ohio 2009). · cites it 2× “This filing created a lien that attached to Jaber’s real property, in this case, the residence. The lien was timely renewed and was not satisfied or released; thus, it remained attached to the property.”
Bill Swad Chevrolet, Inc. v. Dunson, 2019 Ohio 680 (Ohio Ct. App. 2019). · cites it 2× “Swad did not execute on its judgment, and pursuant to R.C. 2329.07(A)(1), Swad's judgment became dormant on June 12, 2007—five years after entry of judgment.”
Show all 41 citing cases →
— Ohio Rev. Code § 2329.07(A) — 3 cases
State v. T.W.C., 2024 Ohio 49 (Ohio Ct. App. 2024).
Hazelwood Assn., Inc. v. Helfrich, 2025 Ohio 2968 (Ohio Ct. App. 2025).
Ohio & Vicinity Carpenters Fringe Benefit Funds, Inc. v. T&M Contractors, LLC (S.D. Ohio 2023).
— Ohio Rev. Code § 2329.07(A)(1) — 5 cases
Columbus Check Cashers, Inc. v. Cary, 962 N.E.2d 812 (Ohio Ct. App. 2011). “25 governs the procedure for the former type of revivor, 1 whereas R.C. 2329.07, 2325.15, and 2325.17 govern the procedure for the latter type of revivor.”
Young v. Locke, 2014 Ohio 2500 (Ohio Ct. App. 2014). “{¶ 6} Thereafter, the trial court vacated the order authorizing the judgment- debtor examination because, pursuant to R.C. 2329.07, a creditor cannot execute on a dormant judgment until the judgment has been revived.”
Bill Swad Chevrolet, Inc. v. Dunson, 2019 Ohio 680 (Ohio Ct. App. 2019). “Swad did not execute on its judgment, and pursuant to R.C. 2329.07(A)(1), Swad's judgment became dormant on June 12, 2007—five years after entry of judgment.”
Selwyn v. Grimes, 2014 Ohio 5147 (Ohio Ct. App. 2014).
Adlaka v. Montella, 2013 Ohio 1276 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 2329.07(A)(l) — 1 case
State v. Farley, 2018 Ohio 4986 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2329.07(B) — 4 cases
Tabbaa v. Lexpro, L.L.C., 2020 Ohio 5514 (Ohio Ct. App. 2020). “R.C. 2329.07(B) (a judgment becomes dormant unless a proceeding in aid of execution is commenced or ongoing); 62 Ohio Jurisprudence 3d, Judgments, Section 137 (providing an example that a judgment entered in another state was not dormant when the judgment creditor filed a…”
State v. Moore, 2021 Ohio 1616 (Ohio Ct. App. 2021). “Appellant opposed the motions arguing that revivor of the dormant judgments was barred by the statute of limitations under R.C. 2329.07 and 2325.18(A). {¶ 5} On July 20, 2020, the trial court granted each of the state’s motions in separate judgment entries.”
Hazelwood Assn., Inc. v. Helfrich, 2025 Ohio 2968 (Ohio Ct. App. 2025).
Brian Walter Ohm (Bankr. N.D. Ohio 2020).
— Ohio Rev. Code § 2329.07(B)(1) — 5 cases
Cornerstone Managed Props., L.L.C. v. Martin, 2025 Ohio 662 (Ohio Ct. App. 2025).
Hazelwood Assn., Inc. v. Helfrich, 2025 Ohio 2968 (Ohio Ct. App. 2025).
Ohio & Vicinity Carpenters Fringe Benefit Funds, Inc. v. T&M Contractors, LLC (S.D. Ohio 2023).
Nationstar Mtge., Inc. v. Scarville, 2024 Ohio 1580 (Ohio Ct. App. 2024).
Autovest, L.L.C. v. Roach, 2026 Ohio 1997 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2329.07(B)(1)(b) — 2 cases
Kittel v. Hunt, 2025 Ohio 4570 (Ohio Ct. App. 2025).
Brian Walter Ohm (Bankr. N.D. Ohio 2020).
— Ohio Rev. Code § 2329.07(C) — 1 case
Marietta v. Verhovec, 2024 Ohio 1184 (Ohio Ct. App. 2024).
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.