How to File a Satisfaction of Judgment in North Dakota
The debtor finally paid. The judgment is satisfied. But your work isn't done — North Dakota law requires you to formally record that the judgment has been paid by filing a Satisfaction of Judgment with the court. Skip this step, and the debtor's credit and property records stay clouded, your liens stay on their real estate, and the debtor can take you to court to force the issue.
The Satisfaction of Judgment Process
Under N.D.C.C. § 28-20-24, the creditor has a statutory obligation to execute and file a Satisfaction of Judgment when the judgment has been paid in full — including principal, accrued interest, and taxable costs.
North Dakota provides an official form for this: Small Claims Form 9 (Satisfaction of Judgment).
The six steps:
Verify full payment. Confirm that the total received covers the original principal, all accrued post-judgment interest under N.D.C.C. § 28-20-34, and any taxable enforcement costs (sheriff fees, garnishment fees, court costs). Use the mandatory allocation order — costs first, then interest, then principal — to confirm the judgment balance is zero.
Complete Form 9. The form requires the case number, court, parties' names, the original judgment amount, and a statement that the judgment has been satisfied in full.
Sign before a Notary Public or Clerk of Court. The form must be notarized or acknowledged before the Clerk of District Court. This is a verification step — an unsigned or unnotarized satisfaction is invalid.
Serve a copy on the debtor by first-class mail. Keep a record of the mailing.
File the original Form 9 with the Clerk of District Court, along with a completed Declaration of Service by Mail (Form 6) proving you mailed the copy to the debtor.
The Clerk notes satisfaction in the judgment docket. This formally discharges the judgment and releases all recorded liens across every county where the judgment was docketed or transcripted.
Filing fee: $0. There is no charge for filing a Satisfaction of Judgment in North Dakota.
What If You Don't File
This isn't optional. If you receive full payment and fail to file the satisfaction:
- The judgment remains on the court's docket as an active, unsatisfied judgment
- Judgment liens on the debtor's real property persist, clouding their title
- The debtor may be unable to sell or refinance property
- Active garnishments based on the judgment continue running
The debtor's remedy: they can file a motion under N.D.R.Ct. 7.1 asking the court to declare the judgment satisfied and present proof of payment, such as canceled checks, bank records, or receipts.
Partial Satisfaction
If you've agreed to accept a reduced amount in full settlement (a negotiated payoff), the satisfaction should state the agreed-upon terms. The form accommodates this — you note that the judgment is satisfied pursuant to the parties' settlement agreement.
If the debtor has only made a partial payment and hasn't agreed to a settlement, you wouldn't file a satisfaction. The judgment remains active for the remaining balance, and any liens and enforcement tools continue in effect.
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Multi-County Cleanup
If you transcripted the judgment to other counties to establish liens on property there, filing the satisfaction in the originating county should discharge liens across all counties where the judgment was recorded. However, it's good practice to confirm with the Clerk of District Court in each county that the satisfaction has been processed and the lien released, particularly if a real estate transaction is pending.
Timing
File the satisfaction promptly after receiving full payment. North Dakota law doesn't specify a statutory deadline by which the satisfaction must be filed, but unreasonable delay exposes you to the debtor's motion for court-ordered satisfaction — and any argument that the delay was intended to harm the debtor could invite sanctions.
For the complete process of managing partial payments, calculating when the judgment is truly satisfied (including the interest allocation rules under N.D.C.C. § 28-20-36), and filing the paperwork to close the case, see our North Dakota judgment collection guide.
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