Michigan Satisfied Judgment: How to File Form MC 17 and Close Your Case

The Judgment Is Paid — Now What?

The debtor finally paid everything they owe — principal, post-judgment interest, and all the enforcement costs you advanced. Congratulations. But you're not done yet.

Michigan law requires you to formally close the case by filing a satisfaction of judgment and releasing any active enforcement instruments. Skipping this step leaves the debtor with an outstanding judgment on their record and your enforcement tools running in the background.

Step 1: File Form MC 17 (Certificate of Satisfied Judgment)

SCAO Form MC 17 is the official record that your judgment has been paid in full. Under MCR 2.620, you (the judgment creditor) sign it and file it with the District Court clerk where the judgment was originally entered.

The form requires:

• The court name, case number, and caption
• A statement that the judgment has been fully satisfied
• Your signature as creditor or attorney
• The date of satisfaction

There's no filing fee for Form MC 17. The clerk enters it into the court record, and the judgment is marked as satisfied in the court's system.

Timing matters. File the satisfaction promptly after receiving full payment. If you do not file it, the debtor may ask the court to enter an Order of Satisfaction.

Step 2: Release Active Garnishments (Form MC 50)

If you have any active writs of garnishment outstanding — whether they're wage garnishments (MC 12), bank garnishments (MC 13), or tax intercepts (MC 52) — release them after full satisfaction. For periodic garnishments, MCL 600.4012 requires the release within 21 days after full payment.

File Form MC 50 (Garnishment Release) and serve a copy on every active garnishee. This tells the employer, bank, or state treasurer to stop withholding and release any funds currently being held.

If a garnishee is in the middle of the 28-day holding period when you file MC 50, the held funds go back to the debtor, not to you. The judgment is satisfied — you don't get to double-collect.

Failing to release garnishments can leave funds being withheld after the judgment has been satisfied, so send the release promptly and reconcile any remaining payments.

Step 3: Discharge Any Judgment Liens

If you recorded a judgment lien (Form MC 94) with the Register of Deeds on the debtor's real property, you need to clear it.

Record a certified copy of the Certificate of Satisfied Judgment (MC 17) or a formal Lien Discharge with the Register of Deeds in every county where you filed the original lien. The standard recording fee is $30 per county.

Until you record the discharge, the lien remains a cloud on the debtor's title. If the debtor tries to sell or refinance and your lien is still showing, it blocks the transaction — and the debtor has a legitimate complaint against you for failing to release it after satisfaction.

Calculating Full Satisfaction

Before you file MC 17, make sure you've actually been paid in full. "Full" includes:

• Principal judgment amount — the original dollar figure the judge awarded
• Court costs awarded at trial — filing fee, process service costs awarded in the judgment
• Post-judgment interest — accruing from the date the complaint was filed until payment; the applicable rate depends on whether the judgment is based on a written instrument or is a general/non-contract judgment under MCL 600.6013
• Enforcement costs you advanced — every filing fee, service fee, disclosure fee, witness fee, and mileage charge you paid out of pocket during collection

Payment credits are applied first to costs, then to interest, then to principal. Don't file the satisfaction until every category is zeroed out.

If the debtor sends a check that covers everything except $47 in enforcement costs, the judgment is not satisfied. Send a written accounting showing the remaining balance.

What If the Debtor Paid Partially?

Partial payment doesn't trigger MC 17. You only file a satisfaction when the entire balance — principal, interest, and costs — is paid. If the debtor made payments through garnishment or direct payment that reduced the balance but didn't eliminate it, keep your enforcement tools active and your ledger current.

You can acknowledge partial payments on your garnishment accounting (Item 2 of MC 12 requires you to itemize credits), but the case stays open until the balance hits zero.

Keep Your Records

Even after filing MC 17 and releasing everything, keep your records — payment receipts, garnishment disclosures, ledger, copies of filed forms — for at least a year. Occasionally a debtor disputes whether they actually paid in full, or a garnishee claims they're owed a refund for over-withholding. Your documentation resolves these disputes.

The Michigan Judgment Collection Guide includes a satisfaction checklist that walks through each step — from verifying the final balance to filing MC 17 to discharging liens — so nothing gets missed when you're closing out the case.

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