Judgment Lien Duration & Renewal Requirements in Tennessee
At a glance
| Governing law | T.C.A. § 28-3-110(a)(2) (10-year limitation on actions upon judgments); T.C.A. § 25-5-101 (creating a real-property lien by registering a certified copy of the judgment); T.C.A. § 25-5-105 (how long that registered lien lasts); Tenn. R. Civ. P. 69.04 (the motion-to-extend-the-judgment procedure) and 69.07 (how the lien is created, extended, and terminated) |
|---|---|
| How long the judgment itself lasts | Generally 10 years from entry (T.C.A. § 28-3-110(a)(2)), extendable for successive 10-year periods by a timely Tenn. R. Civ. P. 69.04 motion. A late motion is time-barred even if styled as scire facias (Town & Country Jewelers, Inc. v. Sheriff). Statutory exceptions have no action deadline: qualifying criminal-injury or converted-restitution judgments under § 28-3-110(b), and domestic-relations judgments unless Title 36 says otherwise under § 28-3-110(e) |
| How long a recorded lien lasts | The SAME clock as the judgment's own 10-year life, not an independent number, unlike states that run the two on separate tracks. T.C.A. § 25-5-105(a) is explicit: a registered judgment lien 'will last for the time remaining in a ten-year period from the date of final judgment entry in the court clerk's office.' A lien registered five years into the judgment's life, for example, only has five years left to run, not a fresh 10. This 10-year figure is itself relatively recent: before a May 17, 2000 amendment, a Tennessee judgment lien lasted only 3 years (or the judgment's remaining life, if shorter), and the amendment expressly does not revive any lien that had already expired before that date (§ 25-5-105(b)) |
| How to renew | Two separate steps. First, file a Tenn. R. Civ. P. 69.04 motion with the court and mail it to the debtor's last known address; if no response is filed within 30 days, 'the motion shall be granted without further notice or hearing.' Second, to keep an existing real-property lien enforceable, register the extension order where the judgment lien was originally registered under Rule 69.07(2). Extending the judgment alone does not preserve the lien |
| Renewal window | File the Rule 69.04 motion before the current 10-year period expires. Timely filing controls even if the court acts later (In re Hunt), and the added 10 years run from expiration of the prior period rather than from the extension-order date (Cook v. Alley). A filing after expiration is untimely, including a motion for scire facias (Town & Country Jewelers, Inc. v. Sheriff). The rules provide no grace period for separately registering the extension order to continue the lien |
| Recent changes or debt-type limits | Rule 69.04 was rewritten effective July 1, 2016 to replace the show-cause procedure with an uncontested 30-day motion process. Section 28-3-110(b) removes the ordinary deadline for qualifying criminal-injury judgments and converted restitution orders, while subsection (e) removes it for domestic-relations judgments unless Title 36 specifically provides otherwise. The 10-year lien duration dates to the May 17, 2000 amendment to § 25-5-105. No current Tennessee bill changes these rules |
| What ends the lien early | Satisfaction allows the debtor to demand a termination statement; failure to register it within 10 days exposes the creditor to $100 plus resulting loss (Rule 69.07(5)). For an ordinary judgment, lapse of the 10-year period without a timely Rule 69.04 motion ends ordinary enforceability and the tied lien period. A post-expiration scire facias filing does not cure the missed Rule 69.04 deadline (Town & Country Jewelers, Inc. v. Sheriff) |
| Recording in more than one county | Yes. A judgment lien on real property is 'created by registering a certified copy of the judgment in the register's office of the county where the realty is located' (Tenn. R. Civ. P. 69.07(2)): a creditor pursuing a debtor's property across county lines must register separately in each county. The same rule applies to keeping the lien alive on extension: the creditor 'must register the court's order extending the judgment' in the records of the register of deeds where the lien was ORIGINALLY registered, meaning that step also has to be repeated in every county where a lien exists, not just the county of the original case |
Requirements one by one
Governing law
T.C.A. § 28-3-110(a)(2) sets the judgment's own 10-year enforceability window. T.C.A. §§ 25-5-101 and 25-5-105 govern how a real-property lien gets created (by registering a certified copy of the judgment) and how long it lasts. Tenn. R. Civ. P. 69.04 is the extension-motion procedure, and Rule 69.07 spells out exactly how the lien is created, extended, and terminated in practice.
How long the judgment itself lasts
For most judgments, 10 years from entry under T.C.A. § 28-3-110(a)(2). Rule 69.04 permits successive 10-year extensions, but each motion must be filed within the period then running. A motion filed after expiration is untimely even if it asks for scire facias revival. Section 28-3-110 has important exceptions: qualifying criminal-injury judgments and converted restitution orders under § 28-3-110(b), and domestic-relations judgments under § 28-3-110(e), have no action deadline unless another law specifically supplies one.
How long a recorded lien lasts
Exactly as long as whatever time remains in the judgment's own 10-year period, not a separate number. T.C.A. § 25-5-105(a) states the registered lien "will last for the time remaining in a ten-year period from the date of final judgment entry." Register the lien five years after judgment, and it only has five years left, not a fresh 10. This 10-year duration itself is relatively recent: before a May 17, 2000 change, a Tennessee judgment lien lasted only 3 years regardless of the judgment's own life, and that change didn't revive any lien that had already expired.
How to renew
Two separate acts, not one. First, extend the JUDGMENT: file a motion under Rule 69.04 and mail a copy to the debtor's last known address. If the debtor does not respond within 30 days, "the motion shall be granted without further notice or hearing" and the court enters an extension order. But that alone does not preserve a recorded LIEN. Separately, "for the extension of the lien to be enforceable, the judgment creditor must register the court's order extending the judgment" where the lien was registered (Rule 69.07(2)).
Renewal window
File the Rule 69.04 motion before the current 10-year period runs out; timely filing controls even if the court rules later (In re Hunt, 323 B.R. 665 (Bankr. W.D. Tenn. 2005)). Once granted, the added period runs from expiration of the prior 10 years, not from the order date (Cook v. Alley, 419 S.W.3d 256 (Tenn. Ct. App. 2013)). A post-expiration filing is too late: Town & Country Jewelers, Inc. v. Sheriff affirmed denial of a motion for scire facias filed more than two years after the deadline because Rule 69.04 required filing within ten years.
Recent changes or debt-type limits
The 2016 amendment to Rule 69.04 replaced the old show-cause procedure with an uncontested 30-day motion process. Separate statutory carve-outs matter: § 28-3-110(b) removes the ordinary deadline for qualifying criminal-injury judgments and converted restitution orders, and subsection (e) does the same for domestic-relations judgments unless Title 36 says otherwise. The 10-year lien duration dates to the May 17, 2000 amendment to § 25-5-105. No current Tennessee bill changes these rules.
What ends the lien early
Full payment, formally cleared: once satisfied, the debtor can demand that the creditor register a termination statement; failure to do so within 10 days makes the creditor liable for $100 plus resulting loss (Rule 69.07(5)). For an ordinary judgment, non-extension also ends the lien because its period is tied to the judgment's 10-year clock. A creditor cannot restore ordinary enforceability by waiting until after expiration and filing for scire facias; Town & Country Jewelers, Inc. v. Sheriff treats that filing as untimely under Rule 69.04.
Recording in more than one county
Yes. A judgment lien is "created by registering a certified copy of the judgment in the register's office of the county where the realty is located" (Rule 69.07(2)), a creditor after a debtor's property in more than one Tennessee county has to register separately in each. The same goes for keeping the lien alive on extension: the court's extension order has to be registered "where the creditor originally recorded the judgment," meaning separately in every county where a lien already exists.
What trips people up
The single biggest trap is assuming that a granted extension motion automatically protects the recorded lien, it doesn't. A creditor can win the Rule 69.04 motion, extend the judgment for another 10 years, and still lose the real-property lien by forgetting to separately register the extension order. The second trap is waiting until after expiration: Tennessee's Court of Appeals has rejected a late scire facias motion because Rule 69.04 requires filing within the 10-year period.
Common questions
I got my Tennessee judgment extended by the court. Is my recorded lien automatically extended too? No. Extending the judgment under Rule 69.04 is a separate step from keeping the lien alive. You must also register a certified copy of the court's extension order with the register of deeds where the lien was originally recorded, skip that and the lien lapses even though the judgment itself survives.
My 10 years already ran out and I never filed a motion. Can I use scire facias? Not for an ordinary judgment. Town & Country Jewelers, Inc. v. Sheriff held that a scire facias motion filed after the 10-year deadline was untimely under Rule 69.04. Check whether a specific statutory exception applies, such as § 28-3-110(b) or (e), but do not assume a late revival action fixes the missed deadline.
Do I need to go to a hearing to get my judgment extended? Not if it's uncontested. Since a 2016 rule change, if you file your extension motion on time and the debtor doesn't respond within 30 days, the court must grant the extension automatically, with no hearing required.
Statutes and sources
- T.C.A. § 28-3-110(a)(2), (b), (e), ordinary 10-year period plus the criminal-injury, restitution, and domestic-relations exceptions quoted in the source record. https://unicourt.github.io/cic-code-tn/transforms/tn/octn/r76/gov.tn.tca.title.28.html (accessed 2026-08-24)
- T.C.A. § 25-5-101, registration creates the real-property lien. https://unicourt.github.io/cic-code-tn/transforms/tn/octn/r76/gov.tn.tca.title.25.html (accessed 2026-08-24)
- T.C.A. § 25-5-105, the lien lasts for the time remaining in the judgment's 10-year period. https://unicourt.github.io/cic-code-tn/transforms/tn/octn/r76/gov.tn.tca.title.25.html (accessed 2026-08-24)
- Tenn. R. Civ. P. 69.04, current extension procedure quoted in the source record. https://www.shelbycountytn.gov/DocumentCenter/View/26110/CRP_amendment?bidId= (accessed 2026-08-24)
- Tenn. R. Civ. P. 69.07, "A judgment lien against the judgment debtor's realty is created by registering a certified copy of the judgment in the register's office of the county where the realty is located.... For the extension of the lien to be enforceable, the judgment creditor must register the court's order extending the judgment.... If the judgment creditor fails to register a termination statement within ten days after demand, the judgment creditor shall be liable to the judgment debtor for $100...." https://www.tncourts.gov/courts/rules-civil-procedure/rules/rules-civil-procedure-rules/rule-6907-execution-realty (accessed 2026-07-09)
- Town & Country Jewelers, Inc. v. Sheriff, No. W2017-01375-COA-R3-CV (Tenn. Ct. App. June 13, 2018), a post-expiration scire facias motion was untimely under Rule 69.04. https://www.courtlistener.com/opinion/4506626/town-country-jewelers-inc-v-andrew-timothy-sheriff/ (accessed 2026-08-24)
Source links
Every statute quoted above, linked, with the date we checked it.
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