Presumed Satisfied at Ten

Alabama Judgment Collection

Alabama does not put judgments to sleep and it does not simply expire them. It shifts the burden. Under Ala. Code 6-9-191, once ten years have passed from entry without an execution issuing – or ten years since the date of the last execution issued – the judgment “must be presumed satisfied, and the burden of proving it not satisfied is upon the plaintiff.” Execution after that needs revival by motion or action under the Rules, and Ala. Code 6-9-190 puts an absolute wall behind it: a judgment cannot be revived after twenty years from its entry. The lien meanwhile is created somewhere unusual – by filing a certificate of the clerk or register with the judge of probate of a county – and it reaches, in that county, all property of the defendant subject to levy and sale, not merely land. Because the presumption is measured from the last execution, Alabama is one of the few states in the region where diligence genuinely moves the date. Knowing where the property and the certificates are is a records question, and it is ours. The research behind this page draws on Alabama probate books, court files and lawfully licensed sources, and starts only where the reason for asking is one the law allows. No investigative licence is held here; nobody practises law or collects debts. Treat all of it as general information on Alabama law and not as an opinion about any particular judgment.

The Probate Office Creates the Lien A Presumption, Not an Expiry Since 2004
Judge of ProbateWhere the Certificate Is Filed
Ten YearsTo the Presumption of Satisfaction
Twenty YearsThe Outer Bar on Revival
Since 2004Researching Recorded Property

The Lien Is Created in a Probate Office

And the certificate that creates it is, by statute, a document about a person.

Alabama does not use a recorder of deeds or a circuit clerk for this. Under Ala. Code 6-9-210, the owner of any judgment entered in any court of this state, or of the United States held in this state, may file in the office of the judge of probate of any county of this state a certificate of the clerk or register of the court that entered it.

The statute then specifies what that certificate must show, and the list is longer than most creditors expect: the style of the court which entered the judgment; the amount and date of it; the amount of costs; the names of all parties; and the name of the plaintiff’s attorney. The judge of probate registers it in a book kept for that purpose, which must also show the date of the filing; makes a proper index showing, under the proper letter or letters of the alphabet, the names of each and every defendant; and records the judgments in chronological order of filing. And the section closes with a requirement that sits oddly in a lien statute until you think about what a lien index is for: “Such certificate shall also show the address of each defendant or respondent, as shown in the court proceedings.”

Two practical points follow. Because the filing is county by county in any county of the state, the question of which probate offices should hold a certificate is an asset-mapping question – the certificate does no work in a county where the debtor holds nothing, and does not reach a county where nobody filed it. And because the index is by defendant name and alphabet letter and the certificate carries a court-derived address, the accuracy of how a debtor is named and located in the underlying proceedings propagates directly into whether anyone can find the lien later. Getting the debtor correctly identified before filing is described in our work on judgment debtor location.

It Reaches More Than Land, and Runs From the Judgment

Ala. Code 6-9-211 is broader in reach and shorter in life than it first appears.

Ala. Code 6-9-211 provides that every judgment, a certificate of which has been filed as provided in 6-9-210, “shall be a lien in the county where filed on all property of the defendant which is subject to levy and sale under execution, and such lien shall continue for 10 years after the date of such judgment.”

Both halves of that sentence deserve attention. On reach, Alabama’s judgment lien is not confined to real estate the way most states’ are; it covers all property in that county which execution could touch, which makes the question of what a debtor holds there – equipment, vehicles, an interest in land – a broader enquiry than a title search. On duration, the ten years run from the date of the judgment, not from the date the certificate reached the probate office. Filing late does not delay the end; it shortens the lien. That is the same asymmetry Tennessee, the Carolinas and Virginia each express differently, and Alabama’s version has the extra sting that the lien it shortens is a wider one.

The section then supplies a tolling rule that no competing page mentions. Where an action or other proceeding to enforce or foreclose the lien is instituted or begun within the ten years but has not been completed, decided or determined within that period, and where at the time the action was begun, or the lien claimed in it, a lis pendens notice was filed in the office of the judge of probate of the county in which the property is situated, the lien continues as to the property claimed in that action and may be enforced or foreclosed in it as if the ten-year period had not elapsed. So an action started in time, with a lis pendens on file, does not die because the litigation outlasted the lien.

Two more rules close the section. No insolvency proceeding or declaration of insolvency affects or impairs the lien, except bankruptcy proceedings instituted within four months after the certificate of judgment was filed for record. And filing the certificate as provided in 6-9-210 is notice to all persons of the existence of the lien – which is what makes the probate index, rather than actual knowledge, the operative fact. Where a debtor has already moved property out of reach, the documented chain matters more than a conclusion about intent, which is the subject of tracing fraudulent transfers by a judgment debtor.

Watch: A Presumption, Not an Expiry

Why Alabama’s ten years shift a burden rather than close a door.

▶ Video Overview

Three Clocks, and Only One of Them Is a Deadline

Alabama’s regime is a presumption behind a wall, and it rewards diligence.

ProvisionWhat happensThe event it runs from
Ala. Code 6-9-191The judgment “must be presumed satisfied“, and the burden of proving it not satisfied is upon the plaintiff.Entry, where ten years pass without an execution issuing – or the date of the last execution issued. Moves
Ala. Code 6-9-192No execution may issue on a district or circuit court judgment on which an execution has not been sued out within ten years of entry until it has been revived by appropriate motion or action under the Alabama Rules of Civil Procedure.Entry.
Ala. Code 6-9-190A judgment “cannot be revived“.Twenty years from its entry. An absolute outer bar.
Ala. Code 6-9-211The lien on all property subject to levy and sale in the county ends.Ten years after the date of the judgment, subject to the lis pendens tolling.

Read the first row carefully, because it is what makes Alabama its own regime rather than a variation on anyone else’s. Ala. Code 6-9-191 does not extinguish anything. It creates a rebuttable presumption of satisfaction and puts the burden of rebutting it on the judgment creditor. A ten-year-old Alabama judgment is not void; it is a judgment the plaintiff now has to prove is unpaid.

And the measure is the alternative in the second limb: ten years since the date of the last execution issued. Unlike South Carolina, where the statute says the period runs whether or not any return has been made, Alabama’s date moves every time an execution issues. A creditor who keeps executions going does not reach the presumption on the schedule that entry alone would set. That is a genuine strategic difference and it is why the execution history in the court file is a fact worth establishing rather than assuming.

The second row is the practical consequence. Ala. Code 6-9-192 bars an execution issuing on a district or circuit court judgment on which none was sued out within ten years of entry until the judgment has been revived – and it specifies the vehicle only as “appropriate motion or action under the Alabama Rules of Civil Procedure”, so which rule applies in a given case is a question for counsel rather than something this page will name.

The third row is the wall. Ala. Code 6-9-190 is a single clause: a judgment cannot be revived after the lapse of twenty years from its entry. Behind it, nothing works. So the overall shape is ten years to a presumption that can be rebutted or reset, revival available in the space beyond it, and an absolute stop at twenty from entry. Across states, the comparison sits in how long a judgment is good for by state, and the mechanics of restarting a lapsed judgment in renewing an old judgment before it expires.

Three Categories Leviable, and One Notable Exclusion

Ala. Code 6-9-40, counted from the enacted text.

Executions may be levied on three things and the statute is specific about each. (1) Real property to which the defendant has a legal title or a perfect equity, having paid the purchase money, or in which he has a vested legal interest in possession, reversion, or remainder, whether he holds the entire estate or is entitled to it in common with others. (2) Personal property of the defendant, except things in action, whether he has absolute title or only the right to possession for his own life, the life of another, or any shorter period – but not a possession acquired by a bona fide hiring of chattels. (3) An equity of redemption in either land or personal property; and where any interest less than the absolute title is sold, “the purchaser is subrogated to all the rights of the defendant and subject to all his disabilities.”

Two features are worth drawing out. Paragraph (1)’s inclusion of a perfect equity where the purchase money has been paid, and of vested interests in reversion or remainder, means an Alabama execution can reach positions that never appear as clean fee title in a deed index – which makes the underlying instruments, rather than a name-and-parcel lookup, the thing worth reading. Paragraph (2)’s exclusion of things in action is a genuine limit and a genuine contrast: North Carolina’s execution statute expressly puts certain choses in action inside execution, and Alabama’s expressly leaves them out. A debtor whose principal asset is a claim against somebody else is in a materially different position on each side of that state line.

Paragraph (3)’s subrogation clause cuts both ways for a purchaser at execution sale, and is a reminder that what is bought at such a sale is the defendant’s position rather than a clean one. That is a legal question and not ours; identifying whether the debtor holds an equity of redemption at all is a records question and is. The general approach is set out in what assets can be seized to satisfy a judgment.

Three Different Exemption Figures, and Only One Applies Today

Alabama publishes all of them at once, which is why so much writing gets it wrong.

Look up the Alabama homestead exemption and you can easily come away with three different numbers, all of them real and only one of them operative. It is worth separating them.

The number in the statute book. Ala. Code 6-10-2 still reads that the homestead of every resident, with improvements and appurtenances, not exceeding in value fifteen thousand dollars and in area 160 acres, is exempt from levy and sale under execution or other process for the collection of debts during his or her life and occupancy. It adds two things worth knowing regardless of the figure: where a husband and wife jointly own a homestead each is entitled to claim separately, to the same extent and value as an unmarried individual; and a mobile home or similar dwelling that is the claimant’s principal residence is deemed to be a homestead for the purposes of that section and of 6-10-38 and 6-10-40. Ala. Code 6-10-6 similarly still reads seven thousand five hundred dollars of personal property, selected by the resident and expressly excluding wages, salaries or other compensation, together with all necessary and proper wearing apparel for the resident and family, all family portraits or pictures, and all books used in the family.

The mechanism that overtakes it. Ala. Code 6-10-12 requires the State Treasurer, on 1 July 2017 and at the end of each three-year period after, to adjust each dollar amount in the article – or, after the first time, each adjusted amount – to reflect the cumulative change in the consumer price index for the three-year period ending on the 31 December preceding the adjustment date, rounded to the nearest twenty-five dollars, and to publish the adjusted amounts. Critically, “the adjusted amounts apply to exemptions claimed on or after the April 1 following the adjustment date.”

Which one is live. The Treasury’s published table gives the homestead figure as fifteen thousand five hundred from 1 July 2017, sixteen thousand four hundred and fifty from 1 July 2020, eighteen thousand eight hundred from 1 July 2023 and twenty thousand four hundred and seventy-five from 1 July 2026, with the personal property figure running seven thousand seven hundred and fifty, eight thousand two hundred and twenty-five, nine thousand four hundred and ten thousand two hundred and twenty-five over the same dates. Apply the April rule and the position today is this: the 2023 adjustment governs exemptions claimed now, and the figures published on 1 July 2026 do not apply until 1 April 2027. So the operative pair is eighteen thousand eight hundred and nine thousand four hundred; the newly published pair is real but not yet in force; and the statute book’s figures have not applied for years.

And a fifth figure may be coming. HB96 of the 2026 Regular Session, as enrolled, amends Ala. Code 6-10-2 to give a resident who is 62 years of age or older, or who is an individual with a disability as that term is defined in Section 21-7-1, a separate and substantially larger homestead exemption, with three proof routes for the disability. The same bill adds a new 6-10-1(b) providing that for any case filed under the Bankruptcy Code the amount of the homestead or other exemption is governed by the law in effect on the date the petition is filed – which matters, because it fixes the figure at filing rather than at the date the debt was created. The enrolled copy states that the act becomes effective on 1 June 2026 and certifies passage by the House on 20 January 2026 and by the Senate on 26 February 2026. What it does not show is enactment. The signature lines on the enrolled copy are blank, the act version of the file is not published, the Legislature’s older bill database no longer resolves, and the Secretary of State’s act search returns the same page for every query – so we could not confirm the act number or the Governor’s signature at a primary source. An enrolled bill is not proof of enactment, and this page therefore does not print the amended amount as though it were operative law. If your debtor is 62 or older, or has a disability, read the current text of 6-10-2 before you rely on any figure. Nor does this page resolve whether the triennial adjustment in 6-10-12 escalates the new amount alongside the old one: 6-10-12 adjusts each dollar amount in the article, which textually reaches it, while the Treasury’s published table carries only one homestead line. The two amounts are not on the same footing and that question is left open here rather than settled quietly.

That is a three-way trap, and there is a fourth thing to keep clear of it. Alabama also has a property tax homestead exemption administered by the Department of Revenue, with its own amounts and its own recent legislation, and it is a different exemption in a different title for a different purpose. Material that treats a change to the property-tax exemption as a change to the creditor exemption in 6-10-2 is conflating two unrelated things. The full creditor schedule and its bankruptcy treatment is set out in our Alabama asset exemptions from creditors reference.

One related provision is worth a line for anyone looking at Alabama real estate: Ala. Code 6-10-3 provides that no mortgage, deed or other conveyance of the homestead by a married person is valid without the voluntary signature and assent of the husband or wife, shown by examination before an officer authorised to take acknowledgments and certified substantially in the form prescribed by Section 35-4-29. And on wages, Ala. Code 6-10-7 states Alabama’s rule as a flat seventy-five per cent exemption of wages, salaries or other compensation for personal services rather than as a lesser-of test with a minimum-wage floor, with the federal limit in 15 U.S.C. 1673 applying independently. The same section puts real duties on the garnishee: report a termination of employment and pay in what has been withheld not later than 15 days after it, and after 30 days from the first retention commence paying funds into court monthly or more frequently until the full amount is withheld. The paycheck arithmetic itself belongs to our Alabama wage garnishment laws guide.

What We Can Establish, and What We Will Not Decide

Probate indexes, court files and land records. The conclusions stay elsewhere.

Everything above describes how Alabama’s lien, revival and exemption statutes read. Applying them to a particular judgment is not work this firm undertakes. Nobody here files a certificate with a judge of probate, sues out an execution, moves to revive a judgment, garnishes, or forms a view on whether a homestead claim will stand or whether a presumption of satisfaction can be rebutted. Nobody approaches a judgment debtor for payment. Those are acts for lawyers and courts, and 6-9-191 in particular is a question of proof rather than of records.

What we can establish is the documentary picture those questions rest on: whether the person in the records is the person named in the judgment rather than a namesake sharing an index letter; where in Alabama they can currently be located; which counties hold property recorded in their name and what is registered against it; what the probate indexes already show; what business interests and other recorded holdings exist; and, where the file is available, what the execution history looks like – which matters here more than in neighbouring states because 6-9-191 measures from the last execution issued. Nothing is looked at until the reason for looking has been put in writing and checked against what the law allows; collecting on a money judgment clears that bar.

How that is done has hard limits. Probate offices, circuit clerks, employers and banks all get the same treatment: an approach in our own name, stating what is sought and on whose behalf. Pretexting is not used here, nor an assumed identity, nor any description of the enquirer that is not accurate. The contents of a private financial account are outside what is obtained by any means. No investigative licence sits behind this work and none is asserted – not licensed private investigators, and no attorneys. We are not a consumer reporting agency; what we produce is not a consumer report and must not be used to decide whether a person receives credit, employment, insurance or housing.

There is one kind of enquiry we refuse, and Ala. Code 6-9-210 is why it is stated here rather than tucked away. Alabama creates its lien by publishing, in a county probate book indexed under every defendant’s name, a certificate that the statute requires to carry the address of each defendant as shown in the court proceedings. The instrument that secures the debt is, by design, an instrument that tells the world where someone can be found. Where an enquiry looks aimed at a person who moved because staying was unsafe – a protective order in the file, an address of record that is obviously standing in for a real one, an asserted interest that does not square with the judgment – the request is refused, and refused out loud rather than quietly shelved. A judgment on file makes no difference to that.

Findings arrive with their sources and a candid note on how current and how complete each is, including where the probate index or the court file does not answer the question. Whether a judgment is in fact satisfied is a matter on which Alabama places the burden on the creditor and the decision on a court; no record produced here settles it. This page carries general information about Alabama law and is not legal advice about any judgment.

The Short Version

Alabama creates its judgment lien in a probate office. Under Ala. Code 6-9-210 the judgment owner files, with the judge of probate of any county, a certificate of the clerk or register showing the court, the amount and date, the costs, the names of all parties, the plaintiff’s attorney and the address of each defendant as shown in the court proceedings; the probate judge registers it, indexes every defendant by alphabet letter, and records in chronological order of filing. Ala. Code 6-9-211 makes it a lien in that county on all property subject to levy and sale under execution – not just land – for ten years after the date of the judgment, with the lien continuing where an enforcement action began inside the ten years and a lis pendens was filed in the probate office of the county where the property sits, and with bankruptcy impairing it only if instituted within four months of the filing. The clock itself is a burden, not a deadline: Ala. Code 6-9-191 presumes the judgment satisfied after ten years from entry without an execution, or ten years from the last execution issued, and puts the burden of proving otherwise on the plaintiff. Execution after that requires revival by motion or action under the Rules (6-9-192), and Ala. Code 6-9-190 bars revival altogether after twenty years from entry. Execution reaches three categories under 6-9-40 – real property including a perfect equity and vested reversions, personal property except things in action, and an equity of redemption. General information about Alabama law, not legal advice.

Our Commitment

Alabama rewards a creditor who keeps moving and punishes one who assumes the file is current, because the presumption of satisfaction is measured from the last execution and the lien is measured from the judgment itself. The facts that decide both live in county probate books, circuit court files and land records, and reading them accurately is what we offer: the debtor distinguished from a namesake in an alphabetical index, a current location established, the counties holding recorded property identified along with what is already registered against it, and business holdings surfaced – all of it dated, sourced, and paired with a straight account of what the record does not resolve. Where to file a certificate, whether to move to revive, and how the exemptions fall are matters for your attorney and the court. Lawful records work carried on since 2004, kept within the boundaries described here.

People Locator Skip Tracing Investigation Team – a skip-tracing and documentary-research team reading Alabama probate indexes, circuit court files and lawfully licensed sources since 2004, acting on nothing without a stated and confirmed lawful purpose. Not licensed private investigators, not attorneys, and not a collection agency. General information about Alabama law, not legal advice about any judgment. Last reviewed 2026.

Alabama Judgment Questions

Where is an Alabama judgment lien filed?

With the judge of probate. Ala. Code 6-9-210 allows the owner of a judgment entered in any court of this state, or of the United States held in this state, to file in the office of the judge of probate of any county a certificate of the clerk or register of the court that entered it. The certificate must show the style of the court, the amount and date of the judgment, the amount of costs, the names of all parties, the name of the plaintiff’s attorney, and the address of each defendant or respondent as shown in the court proceedings.

What property does an Alabama judgment lien reach?

More than land. Ala. Code 6-9-211 makes a judgment whose certificate has been filed under 6-9-210 a lien in the county where filed on all property of the defendant which is subject to levy and sale under execution. Filing the certificate is notice to all persons of the lien’s existence, and no insolvency proceeding or declaration of insolvency affects it except bankruptcy proceedings instituted within four months after the certificate was filed for record.

How long does an Alabama judgment lien last?

Ten years after the date of the judgment, under Ala. Code 6-9-211 – measured from the judgment rather than from the date the certificate was filed, so filing late shortens the lien. The section adds a tolling rule: where an action to enforce or foreclose the lien is begun within the ten years but not completed within them, and a lis pendens notice was filed in the probate office of the county where the property is situated, the lien continues as to that property and may be enforced in that action as if the period had not elapsed.

Does an Alabama judgment expire after ten years?

Not exactly. Ala. Code 6-9-191 provides that if ten years have elapsed from entry without an execution issuing, or ten years since the date of the last execution issued, the judgment must be presumed satisfied and the burden of proving it not satisfied is upon the plaintiff. That is a rebuttable presumption with the burden on the creditor rather than an expiry, and because the second limb measures from the last execution, issuing executions moves the date.

How is an Alabama judgment revived?

Ala. Code 6-9-192 provides that no execution shall issue on a judgment of the district or circuit court on which an execution has not been sued out within ten years of its entry until the judgment has been revived by appropriate motion or action under the Alabama Rules of Civil Procedure. The statute identifies the vehicle only in those terms, so which rule and which form of application apply in a particular case is a question for your attorney.

Is there an outer limit on reviving an Alabama judgment?

Yes, and it is absolute. Ala. Code 6-9-190 provides that a judgment cannot be revived after the lapse of twenty years from its entry. So the overall structure is ten years from entry or from the last execution to a presumption of satisfaction that the creditor must rebut, revival available in the space beyond that, and a hard stop twenty years from entry.

What can an Alabama execution be levied on?

Ala. Code 6-9-40 lists three categories. Real property to which the defendant has legal title or a perfect equity having paid the purchase money, or in which he has a vested legal interest in possession, reversion or remainder, whether alone or in common with others. Personal property of the defendant except things in action, whether he holds absolute title or only the right to possession for a life or shorter period, but not a possession acquired by a bona fide hiring of chattels. And an equity of redemption in land or personal property, with a purchaser of any interest less than absolute title subrogated to all the defendant’s rights and subject to all his disabilities.

Which Alabama exemption figures apply right now?

The ones published for the 1 July 2023 adjustment. Ala. Code 6-10-2 and 6-10-6 still read fifteen thousand and seven thousand five hundred dollars, but Ala. Code 6-10-12 requires the State Treasurer to adjust each dollar amount in the article every three years for the cumulative change in the consumer price index, rounded to the nearest twenty-five dollars, with the adjusted amounts applying to exemptions claimed on or after the 1 April following the adjustment date. The Treasury’s published homestead figures run fifteen thousand five hundred, sixteen thousand four hundred and fifty, eighteen thousand eight hundred and twenty thousand four hundred and seventy-five – so the 2023 figures govern claims made now and the 2026 figures apply from 1 April 2027.

File It With the Right Judge of Probate

Alabama creates the lien in a probate office, county by county, and the certificate has to carry each defendant’s name and address as the court proceedings show them. Tell us who the debtor is and the lawful reason for the enquiry, and we will identify the Alabama counties where property is recorded and how the debtor appears in those records – sourced, and as a rule within 24 hours. Contact us and we will say plainly what the records can settle.

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