Pennsylvania Consolidated Statutes

42 Pa. Cons. Stat. § 8104 (2026)

Duty of judgment creditor to enter satisfaction.

✓ current as of May 2026

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§ 8104. Duty of judgment creditor to enter satisfaction.

(a) General rule.--A judgment creditor who has received satisfaction of any judgment in any tribunal of this Commonwealth shall, at the written request of the judgment debtor, or of anyone interested therein, and tender of the fee for entry of satisfaction, enter satisfaction in the office of the clerk of the court where such judgment is outstanding, which satisfaction shall forever discharge the judgment.

(b) Liquidated damages.--A judgment creditor who shall willfully or unreasonably fail without good cause or refuse for more than 90 days after written notice in the manner prescribed by general rules to comply with a request pursuant to subsection (a) shall pay to the judgment debtor as liquidated damages 1% of the original amount of the judgment for each month of delinquency beyond such 90 days, but not less than $250 nor more than $2,500. Such liquidated damages shall be recoverable pursuant to general rules, by supplementary proceedings in the matter in which the judgment was entered.

(June 25, 1997, P.L.321, No.32, eff. imd.)

1997 Amendment. Act 32 amended subsec. (b).

Notes of Decisions

Cited in 31 cases (3 in the last 5 years), 1981–2026 · leading case: Key Sav. & Loan Ass'n v. Louis John, Inc., 549 A.2d 988 (Pa. 1988).

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Key Sav. & Loan Ass'n v. Louis John, Inc., 549 A.2d 988 (Pa. 1988). · cites it 10× “On appeal, [3] this Court affirmed the order denying debtor's request for damages: [T]he term `satisfaction' as used in 42 Pa.C.S. § 8104, in the phrase, `having received satisfaction,' refers to a situation in which a creditor has received payment of the underlying debt…”

Key Sav. & Loan Ass'n v. Louis John, Inc., 605 A.2d 1223 (Pa. 1992). · cites it 18× “Moreover, in my view the existing case law on the applicability of 42 Pa.C.S. § 8104, is at best confusing and at worst incorrect; and this case offered the Court an opportunity to resolve certain issues.”

Pantuso Motors, Inc. v. Corestates Bank, 798 A.2d 1277 (Pa. 2002). · cites it 4× “On May 28, 1997, Pantuso instituted suit against CoreStates, based upon the latter’s failure to timely record satisfaction of the judgment and security interests, and sought statutory damages pursuant to Sections 9 and 10 of the Act of May 28,1715, concerning satisfaction of…”

Wachovia Bank, N.A. v. Ferretti, 935 A.2d 565 (Pa. Super. Ct. 2007). · cites it 3× “Accordingly, Pisani initiated proceedings against Meridian on October 20, 1994, seeking liquidated damages pursuant to 42 Pa.C.S. § 8104. 1 In August of 1995, Pisa- *568 ni’s counsel asked Attorney Ferretti to prepare a praecipe to have the Bucks County action marked satisfied,…”

O'DONOGHUE v. Laurel Sav. Ass'n, 728 A.2d 914 (Pa. 1999). · cites it 6× “[4] Interpreting Sections 681 and 682 to demand *358 a written request would require us to read a limitation into the statute that is not present.”

First Nat'l Consum. Disc. Co. v. Fetherman, 527 A.2d 100 (Pa. 1987). · cites it 6× “00 made by the Court of Common Pleas of Bucks County pursuant to the provisions of the Deficiency Judgment Act, 42 Pa.C.S. § 8104. In this appeal, the appellants raise two issues for our review: FIRST.”

Esb Bank v. Mcdade, 2 A.3d 1236 (Pa. Super. Ct. 2010). · cites it 5× “As Appellant accurately points out in her reply brief, the averments in the petition to open/strike the confessed judgment identified both her request for ESB to mark the confessed judgment satisfied pursuant to 42 Pa.C.S. § 8104 and her *1240 specific request for liquidated…”

Busy Beaver Bldg. Centers, Inc. v. Tueche, 442 A.2d 252 (Pa. Super. Ct. 1981). · cites it 5× “BROSKY, Judge: This appeal concerns an action brought under 42 Pa.C.S. § 8104 1 by appellant-debtors to have a judgment record marked satisfied and to recover liquidated damages from appellee-creditor for its failure to satisfy same.”

Morgan Guar. Trust Co. of New York v. Mowl, 705 A.2d 923 (Pa. Super. Ct. 1998). · cites it 4× “When appellant refused to satisfy the judgment, appellees filed a petition for assessment of damages against appellant under 42 Pa.C.S. § 8104. On April 3, 1997, the trial court entered an order awarding appellees damages under that section in the amount of $32,162.”

First Seneca Bank v. Gusty A.E. Sunseri, 674 A.2d 1080 (Pa. Super. Ct. 1996). · cites it 7× “(Pizza Roma) (collectively, the defendants), pursuant to 42 Pa.C.S. § 8104. The Bank relies upon Marston v.”

Fid. Fed. Sav. & Loan Ass'n v. Capponi, 684 A.2d 580 (Pa. Super. Ct. 1996). · cites it 4× “Furthermore, the Capponis are entitled to liquidated damages because Fidelity Federal failed to mark the Capponis’ judgment satisfied as required by 42 Pa.C.S. § 8104. With respect to Fidelity Federal’s garnishment action against Prime Bank, we find that since the Capponis’ debt…”

Interbusiness Bank v. First Nat. Bank of Mifflin., 318 F. Supp. 2d 230 (M.D. Penn. 2004). “2d at 104 ; see 42 Pa Cons.Stat. § 8104(b) (2002) (“A judgment creditor who shall willfully or unreasonably fail without good cause or refuse .”

Show all 31 citing cases →

— 42 Pa. Cons. Stat. § 8104(a) — 13 cases

Key Sav. & Loan Ass'n v. Louis John, Inc., 605 A.2d 1223 (Pa. 1992). “Moreover, in my view the existing case law on the applicability of 42 Pa.C.S. § 8104, is at best confusing and at worst incorrect; and this case offered the Court an opportunity to resolve certain issues.”

Esb Bank v. Mcdade, 2 A.3d 1236 (Pa. Super. Ct. 2010). “As Appellant accurately points out in her reply brief, the averments in the petition to open/strike the confessed judgment identified both her request for ESB to mark the confessed judgment satisfied pursuant to 42 Pa.C.S. § 8104 and her *1240 specific request for liquidated…”

Hooper v. Commonwealth Land Title Ins., 427 A.2d 215 (Pa. Super. Ct. 1981).

Busy Beaver Bldg. Centers, Inc. v. Tueche, 442 A.2d 252 (Pa. Super. Ct. 1981). “BROSKY, Judge: This appeal concerns an action brought under 42 Pa.C.S. § 8104 1 by appellant-debtors to have a judgment record marked satisfied and to recover liquidated damages from appellee-creditor for its failure to satisfy same.”

Metro Real Est. v. Siaway, M., 247 A.3d 424 (Pa. Super. Ct. 2021).

— 42 Pa. Cons. Stat. § 8104(b) — 9 cases

Pantuso Motors, Inc. v. Corestates Bank, 798 A.2d 1277 (Pa. 2002). “On May 28, 1997, Pantuso instituted suit against CoreStates, based upon the latter’s failure to timely record satisfaction of the judgment and security interests, and sought statutory damages pursuant to Sections 9 and 10 of the Act of May 28,1715, concerning satisfaction of…”

Fid. Fed. Sav. & Loan Ass'n v. Capponi, 684 A.2d 580 (Pa. Super. Ct. 1996). “Furthermore, the Capponis are entitled to liquidated damages because Fidelity Federal failed to mark the Capponis’ judgment satisfied as required by 42 Pa.C.S. § 8104. With respect to Fidelity Federal’s garnishment action against Prime Bank, we find that since the Capponis’ debt…”

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