Tennessee Satisfaction of Judgment: How to Close Your Case

Why Closing the Case Matters

Getting paid feels like the finish line, but in Tennessee there's one more step: formally recording that the judgment is satisfied. If you skip it, the judgment remains on the court docket as unpaid, any recorded liens continue clouding the debtor's property title, and the debtor's employer may continue withholding wages. You also expose yourself to legal liability.

Filing the Satisfaction of Judgment

Once the judgment is paid in full — through garnishment, voluntary payments, a property sale, or any combination — the creditor must:

1. Execute a Satisfaction of Judgment form stating that the judgment has been paid in full, identifying the case number, parties, and date of original entry
2. File it with the General Sessions Court Clerk where the judgment was entered
3. The clerk updates the official court docket to reflect full satisfaction

Most county General Sessions courts have a standard Satisfaction of Judgment form available from the clerk's office. In Shelby County, that's form CV7224. Davidson County treats satisfaction as a notice filing; ask the clerk for its current filing requirements.

Releasing Recorded Liens

If you recorded a judgment lien at a county Register of Deeds, filing the satisfaction with the court clerk isn't enough. You must separately:

1. Prepare a Release of Judgment Lien — a document stating that the lien is released and the underlying judgment is satisfied
2. File the release with the same Register of Deeds where the original lien was recorded
3. If liens were recorded in multiple counties, file a release in each one

Until you record the release, the lien remains an active encumbrance on the debtor's property. Title companies will flag it on any title search, potentially blocking the debtor from selling or refinancing.

Notifying Employers and Banks

If an active wage garnishment is running, notify the court clerk promptly when the judgment is satisfied. Under T.C.A. § 26-2-217(c), once satisfaction is entered of record, the clerk must promptly notify the employer garnishee that the garnishment lien has expired. Sending the employer a direct written notice can also help stop withholding. Continuing to collect after satisfaction constitutes unjust enrichment and potentially violates the Tennessee Consumer Protection Act.

For bank levies, the court clerk generally handles disbursement — but if funds are still being held pending a garnishee answer, notify the clerk promptly so the bank can release any remaining freeze.

What Happens If You Don't File

Failing to release a satisfied judgment can lead to:

• Slander of title claims: The debtor can sue you for damages resulting from the lingering lien — failed real estate deals, higher refinancing costs, or lost business opportunities
• Statutory damages: Failure to release a satisfied recorded lien can expose the creditor to civil liability and statutory damages
• Continued wage withholding: The employer has no way to know the judgment is satisfied unless you or the court notify them. Every dollar withheld after full payment is money you must return

Timing

File the satisfaction as soon as you confirm full payment. "Full payment" means the principal judgment, all accrued post-judgment interest, and all taxable court costs are covered. If you're calculating the payoff amount, use the daily interest formula and compute through the expected date of the final payment.

For the complete case-closure process — including the payoff calculation worksheet, lien release templates, and the satisfaction filing steps for different county courts — the Tennessee Judgment Collection guide covers everything from final payment through document filing.

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