Va. Code » Title 8.01. Civil Remedies and Procedure » Chapter 4. Limitations of Actions » Article 4. Limitations on Enforcement of Judgments and Decrees
Virginia Code

Va. Code Ann. § 8.01-251 (2026)

Limitations on enforcement of judgments

✓ current as of May 2026
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A. No execution shall be issued and no action brought on a judgment dated, extended, or renewed, prior to July 1, 2021, including a judgment in favor of the Commonwealth and a judgment rendered in another state or country, after 20 years from the date of such judgment or domestication of such judgment or 20 years from the date of such extension or renewal of such judgment, whichever is later, unless the period is extended as provided in this section. No execution shall be issued and no action brought on a judgment dated on or after July 1, 2021, including a judgment in favor of the Commonwealth and a judgment rendered in another state or country, after 10 years from the date of such judgment or domestication of such judgment, unless the period is extended as provided in this section, except that no execution shall be issued and no action brought on a judgment dated on or after July 1, 2021, that was created by nonpayment of child support after 20 years from the date of such judgment or domestication of such judgment.

B. The limitation prescribed in subsection A may be extended by the recordation of a certificate in the form provided in subsection G prior to the expiration of the limitation period prescribed herein in the clerk's office in which such judgment is recorded and executed by either the judgment creditor or his assignee or by the judgment creditor's or his assignee's attorney or authorized agent. Recordation of the certificate shall extend the limitations period of the right to enforce such judgment for 10 years from the date of the recordation of the certificate. A judgment creditor or his assignee may record one additional extension by recording another certificate in the form provided in subsection G prior to the expiration of the original 10-year extension of the limitation period, which shall extend the limitations period of the right to enforce such judgment for 10 years from the date of recordation of the second certificate.

The clerk of the court shall index the certificate in both names in the index of the judgment lien book and give reference to the book and page in which the original lien is recorded. This procedure is subject to the exception that if the action is against a personal representative of a decedent, the motion shall be within two years from the date of his qualification, the extension may be for only two years from the time of the recordation of the certificate, and there may be only one such extension.

C. No suit shall be brought to enforce the lien of any judgment, including judgments in favor of the Commonwealth, upon which the right to issue an execution or bring an action is barred by other subsections of this section, nor shall any suit be brought to enforce the lien of any judgment against the lands that have been conveyed by the judgment debtor to a grantee for value, unless the same be brought within five years from the due recordation of the deed from such judgment debtor to such grantee and unless a notice of lis pendens shall have been recorded in the manner provided by § 8.01-268 before the expiration of such five-year period.

D. In computing the time, any time during which the right to sue out execution on the judgment is suspended by the terms thereof, or by legal process, shall be omitted. §§ 8.01-230 et seq., 8.01-247 and 8.01-256 shall apply to the right to bring such action in like manner as to any right.

E. This section shall not be construed to impair the right of subrogation to which any person may become entitled while the lien is in force, provided that he institutes proceedings to enforce such right within five years after the same accrued, nor shall the lien of a judgment be impaired by the recovery of another judgment thereon, or by a forthcoming bond taken on an execution thereon, such bond having the force of a judgment.

F. Limitations on enforcement of judgments entered in the general district courts shall be governed by § 16.1-94.1. For judgments entered in a general district court prior to July 1, 2026, if an abstract of such judgment is docketed in the judgment book of a circuit court, such judgment shall be treated as a judgment entered by the circuit court and may be extended in the same manner as a judgment entered by the circuit court, although the original date of entry of the judgment shall remain the date that was entered by the general district court. Notwithstanding the provisions of subsection B, for judgments entered in a general district court on or after July 1, 2026, for which enforcement is sought by a debt buyer that has purchased any such judgment from the judgment creditor, the judgment creditor's assignee, or another debt buyer, the 10-year limitation period specified by § 16.1-94.1 shall apply regardless of whether an abstract of such judgment is docketed in the judgment book of a circuit court.

G. Any extension of the limitations of the right to enforce a judgment shall conform substantially with the following form:

CERTIFICATE OF EXTENSION OF LIMITATION OF RIGHT TO ENFORCE JUDGMENT LIEN

Place of Record ___________________________________________________________________________

Date Judgment Docketed ___________________________________________________________________________

Judgment Lien Book __________________ Book Page __________________

Name of Judgment Creditor(s) or Assignee(s) ___________________________________________________________________________

Address of Judgment Creditor(s) or Assignee(s) ___________________________________________________

Phone number of Judgment Creditors(s) or Assignee(s) (if available) ___________________________________________________________________________

Name of Judgment Creditor(s) or Assignee(s)' attorney or agent ___________________________________________________________________________

Address of Creditor(s) or Assignee(s)' attorney or agent ___________________________________________________________________________

Name of Debtor(s) ___________________________________________________________________________

I/we, the undersigned [ ] judgment creditor(s) [ ] agent of judgment creditor(s) [ ] attorney for judgment creditor(s), do hereby certify that the aforementioned judgment lien be extended 10 years from the date of my/our endorsement upon this certificate.

[ ] Judgment creditor(s) or assignee(s) [ ] agent of judgment creditor(s) or assignee(s) [ ] attorney for judgment creditor(s) or assignee(s): ________________

Commonwealth of Virginia

County/City of ____________________

Subscribed, sworn to and acknowledged before me by

_______________, this _____ day of ________, 20 _____

My Commission expires: ____________________

Notary Public: ____________________

Code 1950, §§ 8-393, 8-394, 8-396, 8-397; 1956, c. 512; 1958, c. 221; 1960, c. 274; 1977, c. 617; 1983, c. 499; 2002, c. 394; 2005, cc. 139, 203; 2021, Sp. Sess. I, c. 486; 2022, c. 324; 2026, c. 848.

Notes of Decisions
Cited in 16 cases (2 in the last 5 years), 1984–2023 · leading case: Carter v. Carter, 349 S.E.2d 95 (Va. 1986).
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Carter v. Carter, 349 S.E.2d 95 (Va. 1986). · cites it 20× “Also at issue is the constitutional validity of this provision when viewed in conjunction with Code § 8.01-251, [2] which provides a 20-year period for enforcement of judgments.”
Adcock v. Com., Dept. of Soc. Servs., 719 S.E.2d 304 (Va. 2011). · cites it 34× “Acting upon Houchens' request, on July 7, 2008, DCSE moved the Circuit Court of the City of Alexandria to re-open the parties' divorce, establish the child support arrearage and interest, and set a payment plan.”
Sch. Bd. v. United States Gypsum Co., 360 S.E.2d 325 (Va. 1987). · cites it 4× “"); Code § 8.01-251 ("No action [shall be] brought on a judgment .”
Bennett v. Commonwealth, 422 S.E.2d 458 (Va. Ct. App. 1992). · cites it 8× “It is only once such a judgment for a sum certain is obtained that Code § 8.01-251, in contrast to Code § 8.”
Adcock v. Com., Dept. of Soc. Servs., 693 S.E.2d 757 (Va. Ct. App. 2010). · cites it 68× “ANALYSIS Appellant contends the twenty-year statute of limitations set forth in Code § 8.01-251 [3] bars appellee's enforcement of the 1966 child support order.”
Wells Fargo Equip. Fin. v. Nabil Asterbadi, 841 F.3d 237 (4th Cir. 2016). “See Va. Code Ann. § 8.01-251 (A). While Asterbadi made a number of payments on the judgment during the period shortly after it was entered, the judgment has, in substantial part, remained unsatisfied.”
Johnston Mem'l Hosp. v. Hess, 44 B.R. 598 (W.D. Va. 1984). · cites it 3× “Va. Code § 8.01-251 D (1984 Repl.Vol.). The Hospital’s lien has not yet expired.”
Payne v. Claffy, 315 S.E.2d 814 (S.C. Ct. App. 1984). “See Va. Code § 8.01-251 (1977). The trial court held in granting Payne summary judgment that no South Carolina statute of limitations barred Payne’s action.”
Flame S.A. v. Indus. Carriers, Inc., 24 F. Supp. 3d 493 (E.D. Va. 2014). “§ 8.01-251(A) (imposing a twenty-year statute of limitations to enforce a judgment).”
Haskins v. Commonwealth of Virginia (E.D. Va. 2022). · cites it 6× “] 198185 stopped in 2013, reopened for interest sought ...on May 24, 2021 and [is] still ongoing.”
Benny McCroskey, s/k/a Benny W. McCroskey v. Commonwealth of Virginia (Va. Ct. App. 2023). · cites it 3× “” McCroskey argued that because more than 20 years had passed since the trial court entered the orders that required McCroskey to pay the court costs on the 1994 and 1996 convictions, Code § 8.01-251 prevents the Commonwealth from recovering the court costs on those convictions.”
Shevlin Smith v. McLaughlin (Va. 2015). · cites it 3× “Once armed with a judgment, a plaintiff then has 20 years to collect that award under Code § 8.01-251(A), 5 which can be frustrated by a number of factors.”
Show all 16 citing cases →
— Va. Code Ann. § 8.01-251(A) — 5 cases
Adcock v. Com., Dept. of Soc. Servs., 719 S.E.2d 304 (Va. 2011). “Acting upon Houchens' request, on July 7, 2008, DCSE moved the Circuit Court of the City of Alexandria to re-open the parties' divorce, establish the child support arrearage and interest, and set a payment plan.”
Adcock v. Com., Dept. of Soc. Servs., 693 S.E.2d 757 (Va. Ct. App. 2010). “ANALYSIS Appellant contends the twenty-year statute of limitations set forth in Code § 8.01-251 [3] bars appellee's enforcement of the 1966 child support order.”
Flame S.A. v. Indus. Carriers, Inc., 24 F. Supp. 3d 493 (E.D. Va. 2014). “§ 8.01-251(A) (imposing a twenty-year statute of limitations to enforce a judgment).”
Haskins v. Commonwealth of Virginia (E.D. Va. 2022). “] 198185 stopped in 2013, reopened for interest sought ...on May 24, 2021 and [is] still ongoing.”
Shevlin Smith v. McLaughlin (Va. 2015). “Once armed with a judgment, a plaintiff then has 20 years to collect that award under Code § 8.01-251(A), 5 which can be frustrated by a number of factors.”
— Va. Code Ann. § 8.01-251(B) — 1 case
Shevlin Smith v. McLaughlin (Va. 2015). “Once armed with a judgment, a plaintiff then has 20 years to collect that award under Code § 8.01-251(A), 5 which can be frustrated by a number of factors.”
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