Satisfaction of Judgment in New York: How to Close Out a Paid Judgment

What a Satisfaction of Judgment Does

A satisfaction of judgment is the official document that tells the world the debt has been paid. Under CPLR 5020, after the debtor pays the full amount owed — including accrued interest and allowable enforcement costs — and makes a written demand, the judgment creditor must execute and file a satisfaction within 20 days.

Filing satisfaction does three concrete things:

1. Releases real property liens — any lien created by docketing the Transcript of Judgment with the County Clerk is discharged
2. Stops further enforcement — no officer can levy accounts, garnish wages, or seize property on a satisfied judgment
3. Updates the public record — the County Clerk's docket shows the judgment as satisfied, which matters when the debtor applies for loans, sells property, or runs a title search

Without a filed satisfaction, the judgment sits on the public record as an open, unsatisfied debt — even if the creditor has been paid in full.

How to File

The creditor prepares an Acknowledgment of Satisfaction — a short document stating that the judgment has been satisfied in full (or partially, if a partial payment was accepted as settlement). The creditor signs and has it notarized.

The signed acknowledgment is filed with the clerk of the court that entered the original judgment. If the judgment was also docketed with a County Clerk (creating a property lien), a copy must be filed there too. Each filing may carry a small administrative fee.

CPLR 5020 requires the creditor to deliver the satisfaction-piece to the debtor or file it with the court clerk. Provide the debtor a copy as proof that the matter is closed.

The 20-Day Rule and Penalties

Here is where creditors get into trouble. CPLR 5020 imposes a 20-day deadline after the creditor receives both full payment and the debtor's written demand.

If the creditor fails to do so, CPLR 5020(c) provides a $100 statutory penalty, plus actual damages caused to the debtor.

This penalty exists because an unsatisfied judgment on the public record is a real obstacle. It clouds title on real property, complicates financing, and creates the false impression that the debtor owes money they have already paid.

Partial Satisfaction

If you accept a settlement for less than the full judgment amount, put the settlement terms in writing before accepting payment. Do not file a full satisfaction unless the remaining balance has been resolved under that agreement.

What If the Debtor Overpays

Enforcement actions can collect more than the remaining balance. Reconcile the officer's accounting against the amount due and promptly contact the enforcement officer about any overage.

Track the running balance — original judgment, interest at the applicable rate, enforcement costs incurred, and payments received — so you know exactly when the judgment is satisfied. Our New York Judgment Collection Guide includes a balance tracker worksheet for this purpose.

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