Michigan Judgment Lien on Property: How to File Form MC 94

If the debtor who owes your Michigan small claims judgment owns real estate, recording a judgment lien is one of the most strategically useful collection tools available. It won't put money in your hand today, but it creates a legal cloud on the property that can prompt payment when the debtor eventually sells, refinances, or transfers the home.

How the Lien Works

Under the Michigan Judgment Lien Act (MCL 600.2801 et seq.), a recorded judgment lien attaches to the debtor's present and future equity interest in real property located in the county where you file. Title companies and mortgage lenders check for liens as part of every transaction — the debtor cannot close a sale or refinance without clearing your lien.

Unlike a mortgage or construction lien, a judgment lien cannot be foreclosed. You cannot force a sale of the property. The lien works passively: it sits on the title and waits.

Step-by-Step Filing Process

1. Prepare Form MC 94

Complete SCAO Form MC 94 (Notice of Judgment Lien). You'll need the case number, court name, parties, judgment date, and the unsatisfied balance including post-judgment interest.

2. Get Court Certification

Submit the completed Form MC 94 to the district court clerk where your judgment was entered. The clerk verifies the judgment details, signs the form, and applies the official court seal. The court typically charges a $15 fee for certification.

3. Record with the Register of Deeds

Take or mail the certified Form MC 94 to the Register of Deeds in the county where the debtor owns property. The standard recording fee is $30. If the debtor owns property in multiple counties, you need to record a separate certified copy in each county — $45 per county ($15 court certification + $30 recording).

4. Serve the Debtor

Under MCL 600.2805(2), you must serve the recorded copy on the debtor. For judgments under $25,000 (which covers all small claims), certified mail is sufficient — you don't need personal service. File a Proof of Service (page 2 of Form MC 94) with the court.

Duration and Renewal

A judgment lien expires five years from the date it's recorded with the Register of Deeds, or when the underlying judgment expires — whichever comes first. Since Michigan judgments last 10 years under MCL 600.5809(3), the lien will typically expire before the judgment does.

You can renew the lien once for an additional five-year period by filing and recording a new certified Form MC 94 before the initial five years expire. If you miss the renewal deadline, the lien lapses and you lose your priority position against other creditors.

Homestead Exemption

Michigan's homestead exemption protects a portion of the debtor's equity in their primary residence from judgment execution. The exempt amount is roughly $30,000 to $45,000 for elderly or disabled homeowners under MCL 600.6023(1)(h)-(i). The lien still attaches to any equity above the exemption — and in a sale, the exemption amount goes to the debtor while the excess (up to your judgment balance) goes to you.

When the property is sold, transferred, or refinanced, the lien can prompt payment from available equity. It cannot be foreclosed, so it does not guarantee recovery.

When to Use This Tool

A judgment lien makes the most sense when:

• The debtor owns real property with equity above the homestead exemption
• Wage and bank garnishments have been slow or unsuccessful
• You're willing to wait for the debtor to sell or refinance
• You want to secure your position against other creditors

At $45 total cost ($15 certification + $30 recording), it's inexpensive insurance. Even if you're actively garnishing wages, recording a lien gives you a backstop in case the debtor quits their job or empties their bank account.

Releasing the Lien After Payment

Once the judgment is fully satisfied, you must record a discharge or file a certified copy of the Certificate of Satisfied Judgment (Form MC 17) with the Register of Deeds. Failing to release a satisfied lien can leave the title record encumbered and create problems for the debtor's future real estate transactions.

For the complete lien filing process integrated into the full enforcement workflow, see the Michigan Judgment Collection Roadmap.

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