Hawaii Satisfaction of Judgment: How to File Form 1DC48

When a debtor pays a Hawaii judgment in full — whether through a lump sum, wage garnishment, bank garnishment, or auction proceeds — the creditor is legally required to file a Satisfaction of Judgment with the court. This is not optional. Failing to do it can leave garnishments running, liens clouding title, and you exposed to liability.

Filing the Satisfaction of Judgment

The form is Satisfaction of Judgment / Release of Garnishee(s):

• Oahu (First Circuit): Form 1DC48
• Big Island (Third Circuit): Form 3DC48

Both are available free on the Hawaii State Judiciary website. Complete the form, sign it, and file it with the District Court clerk where the original judgment was entered.

This form lets you select satisfaction of judgment and/or release of a named garnishee. Select the option or options that apply and serve the garnishee as stated in the form. A satisfaction records that the judgment is paid; a release discharges the named employer or financial institution from its garnishment obligation.

Releasing a Specific Garnishee Before Full Satisfaction

Sometimes you need to release one garnishee while keeping the judgment active — for example, if you garnished the wrong bank account or the debtor changed jobs and you need to redirect the garnishment to a new employer.

For this, file a standalone Release of Garnishee:

• Oahu: Form 1DC45
• Big Island: Form 3DC45

This releases only the named garnishee from its withholding obligation. The underlying judgment stays in effect, and you can file a new garnishee summons against a different employer or bank.

Clearing Real Property Liens

If you recorded the judgment at the Hawaii Bureau of Conveyances to create a lien on the debtor's real property, filing the satisfaction with the court alone is not enough. You must also record a certified copy of the Satisfaction of Judgment at the Bureau to clear the title.

Which system depends on where the original lien was recorded:

• Regular System: $41 recording fee for documents up to 50 pages ($106 for 51 or more pages)
• Land Court System: $36 recording fee for documents up to 50 pages ($101 for 51 or more pages), and the lien annotation must be removed from the debtor's Certificate of Title

Until the Bureau records are cleared, the lien continues to encumber the property even though the debt is paid. This can complicate a sale or refinance, and if you delay, you may face liability for slander of title or improper encumbrance.

When to File

File and deliver the satisfaction promptly after receiving full payment. HRS § 636-3 requires the creditor or attorney to execute, acknowledge, and deliver a satisfaction when the judgment is fully paid, but sets no separate day count. The longer you wait, the more likely the debtor files a motion asking the court to compel you to acknowledge payment — and you may end up paying their costs for the motion.

Keep a detailed payment ledger throughout the collection process. Track every payment received, the date, and how it was applied (first to costs, then to accrued interest at 10% per year under HRS § 478-3, then to principal). This ledger is your proof that the judgment is satisfied and protects you if there is any dispute about the final amount.

What Happens If You Do Not File

If a judgment creditor fails to file a satisfaction after full payment, the debtor can petition the court for relief. The court docket continues to show an unsatisfied judgment, which may affect the debtor's credit, complicate property transactions, and lead to continued garnishment after the debt is already paid. Creditors who fail to provide a satisfaction may face liability for leaving a paid judgment lien in place.

Our Hawaii Judgment Collection Guide walks through every step from enforcement to case closure, including satisfaction forms and lien release procedures for all circuits.

See more Hawaii guides →