Which place’s debt rules apply—and who can help?

S_MT PASS-18 — Montana ordinary consumer-debt court-judgment interest, duration, renewal, satisfaction, and judgment-lien release

Fresh research session: October 26, 2026, Pacific / October 26, 2026, UTC Mode: Regular Chat with public primary-source browsing Relationship to prior work: Distinct judgment component. PASS-17 is saved but unreviewed and is not treated as an accepted premise. The arbitration-award boundary below is based on a fresh read of MCA §27-5-314.

Component status: PARTIAL. Montana’s ordinary state-court postjudgment-interest formula, current 2026 rate, historical transition, ten-year enforcement and lien periods, action-on-judgment route, acknowledgment branch, county-specific lien mechanics, sister-state registration, satisfaction procedure, partial-satisfaction doctrine, and federal/state distinctions are established. Actual judgment dates, contract rates, payments, allocation, ownership, liens in specific counties, tolling, bankruptcy, assignment authority, and local recording practices remain held.

I. Core conclusions

1. A private arbitration award is not yet a Montana court judgment. Once a District Court grants an order confirming, modifying, or correcting the award, judgment must be entered in conformity with that order and may be docketed like a judgment rendered in an action. Only then does the ordinary judgment-interest, lien, and enforcement framework begin to apply. Montana Code Annotated
2. Montana’s default postjudgment rate for judgments entered in calendar year 2026 is 9.75% simple interest. MCA §25-9-205 sets the rate at the Federal Reserve H.15 bank-prime rate established for January 1 plus three percentage points and forbids compounding. The official Federal Reserve/FRED series records 6.75% for January 1, 2026:

6.75%+3.00%=9.75%6.75%+3.00%=9.75%6.75%+3.00%=9.75%The rate applies to judgments entered during 2026 and remains fixed for that judgment; it does not reset each January. Montana Code Annotated+2

1. The 2026 rate is not the rate for every older judgment. The 2017 amendment adopting prime-plus-three did not apply to proceedings begun before July 1, 2017. Those proceedings remain governed by the prior law applicable to them. A judgment’s rate therefore must be reconstructed from the proceeding date, judgment date, statutory version, and any contract-rate branch—not from today’s rate. Justia Law
2. A judgment involving a contractual obligation that specifies an interest rate uses the specified contract rate rather than the default prime-plus-three rate. The statute does not itself authorize compounding under that branch. Compounding would require an independently valid contract term and applicable law; it cannot be inferred merely because the contract states an annual rate. Montana Code Annotated
3. Montana’s default statutory branch is simple interest. It does not compound annually, monthly, or by capitalizing unpaid accrued interest. A later valid new judgment, lawful contract provision, or separate order may alter the interest-bearing base, but none may be assumed from an ordinary unpaid judgment. Montana Code Annotated
4. The rate and the interest-start date are separate questions. Section 25-9-205 fixes the applicable rate by the calendar year of judgment entry. Section 25-9-204 directs the clerk, for a judgment on a verdict or decision, to include interest from the time the verdict was rendered or the decision made. Montana decisions have therefore allowed interest to begin on the verdict or decision date even when formal judgment followed later. Justia Law
5. An appeal or stay of execution does not stop postjudgment interest. Montana’s postjudgment statutes contain no stay exception, and Appellate Rule 19(4) requires interest from the original judgment date when the money judgment is affirmed. Warrington expressly overruled contrary language and held that a stay did not toll interest. Justia Law+1
6. Payment that omits accrued postjudgment interest does not fully satisfy the judgment. In Warrington, the Montana Supreme Court reversed a full-satisfaction ruling because the payment omitted interest accruing during the appeal stay. Full satisfaction ordinarily requires the entire unsatisfied judgment amount, lawful accrued interest, and other judgment components then due. Justia Law
7. Montana’s ordinary judgment enforcement period is ten years. An action on a judgment of a court of record must be commenced within ten years; a judgment of a court not of record receives the same ten-year period, expressly accruing when final judgment is rendered. Execution likewise may issue only within that period. Special support and restitution provisions are outside this report. Montana Code Annotated+1
8. Montana does not provide a routine ex parte “renewal” that simply stamps another ten years onto the old judgment. Before the ten-year period expires, the judgment creditor may file a separate civil action on the judgment and obtain a new judgment. Jones v. Arnold upheld that process and distinguished it from an unsupported ex parte extension. Justia Law+1
9. Filing begins the new action, but valid service remains separately necessary. Montana Rule 3 says filing commences an action. Current MCA §25-3-107 says service must occur within two years, while current District Rule 4(t) says three years. That live conflict has not been resolved for this component, so no safe terminal service date is supplied. Montana Code Annotated+2
10. A signed written acknowledgment of an unsatisfied judgment can restart the judgment limitation period. Montana’s general restart statute says a signed acknowledgment causes the relevant limitation to begin anew. Marriage of Brown followed Montana’s older Dodd rule and applied acknowledgment to judgment obligations. The reviewed case involved an acknowledgment made before the judgments were time-barred. Justia Law+1
11. Do not assume every payment restarts a judgment. MCA §27-2-409 separately references part payment of principal or interest, but Brown did not decide that its periodic-payment facts independently restarted each judgment. The payment must be attributable to the judgment and satisfy the statute; the effect of an ordinary consumer-judgment payment, especially after the original ten-year period, remains unresolved here.
12. A restarted enforcement period does not automatically restart an existing real-property lien. Montana’s judgment-lien statutes supply independent ten-year periods and county-filing prerequisites. A qualifying acknowledgment may affect the action-on-judgment period, but no authority reviewed here says it automatically extends the old lien or preserves its original priority.
13. A Montana District Court judgment becomes a lien only when docketed, and only on nonexempt real property in that county. The lien covers property owned at docketing or acquired before the lien ceases and lasts ten years unless the judgment is sooner satisfied. It is not a statewide lien and is not a lien on every asset. Montana Code Annotated
14. For another Montana county, a certified transcript must be filed with that county’s District Court clerk. The lien there starts on filing but still expires ten years from the original judgment-entry date—not ten years from the later transcript filing. Montana Code Annotated
15. A Justice Court judgment creates no real-property lien until a certified transcript is filed with the District Court clerk in the county where the land is located. The lien then covers nonexempt real property in that county and continues ten years unless sooner satisfied. A Small Claims judgment ordinarily follows the Justice Court structure, although the exact Small Claims transcript form was not readable in this pass. Montana Code Annotated
16. A federal District of Montana or Ninth Circuit judgment likewise requires county filing for a Montana real-property lien. MCA §25-9-303 authorizes filing a certified transcript with a county District Court clerk; the lien then reaches nonexempt real property in that county and lasts ten years unless satisfied. Federal law also makes federal judgment liens conform to state lien conditions. Montana Code Annotated+1
17. Montana recognizes both full and partial satisfaction. Section 25-9-311 permits satisfaction through a returned satisfied execution or a filed acknowledgment or docket endorsement. If payment occurred outside execution, the creditor or authorized attorney must acknowledge it; on motion, the court may compel the acknowledgment or order satisfaction entered without it. Gullett holds that this includes partial satisfaction. Montana Code Annotated+1
18. A debtor cannot automatically dictate how one judgment payment is allocated among damage categories merely by relying on Montana’s general contract-allocation statute. Shilhanek treated judgment allocation as governed by the judgment context and upheld the District Court’s refusal to allocate payment as the debtors requested. Justia Law
19. Montana’s satisfaction statute states no fixed number of days, statutory penalty, or automatic attorney-fee award for failing to file satisfaction. The express remedy is a motion asking the court to compel acknowledgment or order entry. Other contract, tort, or consumer-protection theories would require separate authority and facts.
20. Satisfaction of one judgment does not automatically perform every related task. It does not necessarily:Release a separate settlement agreement.Release unrelated collateral or security.Update every out-of-county transcript lien without additional filing.Delete a credit tradeline.Discharge unrelated obligations.Establish that every payment allocation was correct.
21. A registered sister-state judgment uses Montana’s ten-year enforcement period, measured from the original foreign judgment—not from Montana registration. Oskerson applied Montana law but measured the period from the Arizona judgment’s original entry date. Justia Law+1
22. Federal postjudgment interest is materially different. A federal District Court money judgment uses the weekly average one-year constant-maturity Treasury yield for the calendar week preceding judgment; interest is computed daily and compounded annually. That federal formula does not govern a Montana state-court judgment. U.S. Code

II. Judgment-type and court-route matrix

The ordinary state ten-year provisions reach judgments of courts of record and courts not of record; special support and restitution branches are excluded. Montana Code Annotated+1

III. Interest architecture

A. Prejudgment versus postjudgment interest

Montana uses distinct statutes:

Prejudgment entitlement and calculation remain claim-dependent. This report does not use the 2026 postjudgment rate as an automatic prejudgment rate for every claim. Warrington emphasizes that §§27-1-210–211 and §§25-9-204–205 govern distinct stages. Justia Law

B. Montana default postjudgment formula

For a judgment not governed by the specified-contract-rate branch:

rjudgment year=rH.15 prime on January 1+3.00%r_{\text{judgment year}}

r_{\text{H.15 prime on January 1}} + 3.00%rjudgment year​=rH.15 prime on January 1​+3.00%I=P×r×tI=P\times r\times tI=P×r×twhere:

• PPP = the unsatisfied interest-bearing judgment base.
• rrr = the fixed annual rate for the judgment-entry calendar year.
• ttt = the lawful time fraction.
• No statutory compounding is allowed.

The statute also covers costs incurred to obtain or enforce the judgment. Montana Code Annotated

C. Calendar-year rate, fixed for the life of the judgment

Burns rejected annual repricing. Its construction is:

1. Determine the January 1 prime rate for the calendar year in which judgment is entered.
2. Add three points.
3. Apply that single rate to the judgment while it remains unpaid.

The 2022 judgment in Burns therefore remained at 6.25%, derived from a 3.25% January 1, 2022 prime rate—not whatever prime rate existed in later years. Justia Law

D. Verified 2026 rate

The official H.15/FRED series identifies January 1, 2026 at 6.75%. Thus:

6.75%+3.00%=9.75%6.75%+3.00%=9.75%6.75%+3.00%=9.75%Verified Montana default rate for judgments entered in calendar year 2026: 9.75% simple.

A prime-rate change later in 2026 or 2027 does not reprice that judgment. FRED+1

E. Historical-rate branch

The 2017 legislation was expressly inapplicable to proceedings begun before July 1, 2017. National Indemnity applied the prior law to such a proceeding. Therefore, an older judgment requires:

• Proceeding commencement date.
• Judgment or verdict date.
• Statutory version.
• Any contract interest provision.
• Any later amended judgment or reversal.

No current-rate shortcut is valid for those judgments. Justia Law

F. Contract-rate branch

MCA §25-9-205(2) uses the specified contract rate for a judgment involving that contractual obligation.

Necessary predicates include:

• A valid contract.
• A definite interest rate.
• Proof that the rate applies after judgment.
• No superseding settlement, release, modification, or unlawful-rate rule.
• Identification of the amount to which the rate applies.

The statute does not itself say that the contract rate compounds. Nor does the mere existence of a pre-default annual percentage rate automatically prove a postjudgment compounding right. Montana Code Annotated

G. Interest-bearing components

The postjudgment statute expressly reaches:

• Judgment amounts.
• Costs incurred to obtain the judgment.
• Costs incurred to enforce it.

A separately adjudicated attorney-fee award can itself bear postjudgment interest. Gendron treated postjudgment interest as a statutory right and applied it to an attorney-fee award. The actual start date for a later fee or cost award depends on the order and judgment entering that amount. Justia Law

H. Verdict, decision, and judgment-entry dates

A single case may present two relevant dates:

• Interest start: verdict rendered or decision made under §25-9-204.
• Rate selection: calendar year of judgment entry under §25-9-205 as construed by Burns.

McCulley and Hulstine recognize verdict-date interest in their respective settings. The actual verdict, decision, fee order, amended judgment, and mandate must be read before selecting a date.

I. Appeal, stay, reversal, and modification

If a money judgment is affirmed, Montana Appellate Rule 19(4) continues lawful interest from the original judgment date. A stay of execution does not toll it. Justia Law+1

If the appellate court reverses and requires an entirely new judgment, the mandate and nature of the modification control. A purely mathematical amendment may preserve the original start date; a reversal requiring a new adjudication can produce a different date. No universal “every amended judgment resets interest” rule applies.

J. Payment, tender, and stopping interest

Postjudgment interest stops on an amount when that amount is legally satisfied, paid, deposited, or otherwise extinguished under the governing judgment and law. But:

• A rejected or incomplete tender does not automatically stop interest.
• A stay does not stop interest.
• A payment missing accrued interest is not full satisfaction.
• The actual allocation of a partial payment determines the remaining interest base.
• A court-approved deposit or satisfaction order must be examined on its own terms.

Warrington and Gendron reject the proposition that a stay or unsuccessful tender necessarily ends the statutory right. Justia Law+1

IV. Interest and payment matrix

V. Duration, enforceability, and “dormancy”

A. Ten-year action and execution period

MCA §27-2-201 provides:

• Court of record: action on judgment within ten years.
• Court not of record: action within ten years, accruing when final judgment is rendered.

MCA §25-13-101 permits execution within that same period. Montana Code Annotated+1

B. “Dormancy” terminology

The current ordinary statutes do not establish a separate routine dormancy period followed by an automatic administrative revival. The operative concepts are:

• A ten-year limitation for action on the judgment.
• A ten-year execution period.
• A separate ten-year judgment-lien period.
• A new civil action on the judgment.
• Possible restart from a qualifying acknowledgment.
• Possible statutory suspension or tolling.

Calling a judgment “dormant” does not itself identify which period expired or what step is required.

C. Expiration is not automatic extinguishment of every underlying obligation

Expiration of the ordinary enforcement period bars the identified judicial remedy unless a valid restart, tolling event, or new judgment applies. It does not necessarily erase the historical obligation for every possible purpose. Special statutes declaring a debt void or extinguished are outside this report.

D. Events that do not automatically renew everything

No reviewed authority says the following automatically create a new ten-year judgment, extend the lien, or restore execution:

• Demand letter.
• Collection placement.
• Assignment.
• Sale to a debt buyer.
• Updated account statement.
• New payment plan proposal.
• Execution request.
• Transcript filing in another county.
• Credit reporting.
• Negotiation.
• Informal promise.
• Partial payment whose identity and application are unclear.

E. Tolling and stays

MCA §27-2-406 excludes a period during which commencement of an action is stayed by injunction, court order, or statutory prohibition. Its predicate is a stay of commencement of the action.

An appeal stay that merely bars execution is not automatically the same as an order prohibiting commencement of an action on the judgment. No conclusion is made that every appeal, bankruptcy, death, disability, or collection stay suspends the ten-year period. Those require their own authority and chronology.

VI. Action on judgment, renewal, acknowledgment, and payment

A. New action on the existing judgment

Jones v. Arnold establishes the Montana route:

1. File a separate complaint on the existing unsatisfied judgment before the ten-year period expires.
2. Establish the valid judgment, current ownership, unsatisfied amount, and entitlement.
3. Serve the defendant.
4. Permit applicable defenses.
5. Obtain a new judgment.
6. Docket or transcribe the new judgment to create any new liens.

The new judgment receives its own enforcement period. An ex parte motion simply asking the old court to “extend” the old judgment is not the established route. Justia Law+1

B. Evidence needed

A plaintiff in an action on judgment ordinarily must establish:

• The original judgment and entry date.
• Court jurisdiction.
• Finality or present enforceability.
• Current creditor or valid assignee status.
• Payments and credits.
• Accrued lawful interest and costs.
• Lack of full satisfaction, release, discharge, or vacatur.
• Timely commencement.
• Valid service in the new action.

The defendant may raise satisfaction, partial satisfaction, lack of ownership, invalidity, jurisdiction, limitations, discharge, or other available defenses.

C. Commencement and service

Rule 3 says filing the complaint commences the action. Current MCA §25-3-107 says service within two years; Rule 4(t) says three. This report preserves that conflict and supplies no safe individualized deadline. Montana Code Annotated+2

D. Signed acknowledgment

Section 27-2-409 requires a signed writing for acknowledgment. Marriage of Brown treated a signed stipulation acknowledging unsatisfied arrearage judgments as restarting/tolling the judgment limitation. Justia Law+1

A qualifying writing should clearly identify:

• The judgment.
• The debtor.
• The unpaid status.
• The obligation acknowledged.
• The signer’s identity and authority.

A settlement inquiry, dispute, document request, or conditional proposal does not automatically satisfy that standard.

E. Part payment

The general statute includes payment of principal or interest, but the reviewed judgment-specific cases do not establish that every payment on an ordinary consumer judgment restarts the ten-year period.

Held questions include:

• Was the payer the debtor or an authorized agent?
• Was the payment actually applied to the judgment?
• Was it principal or interest?
• Was it reversed?
• Was it made before or after expiration?
• Did the payment acknowledge the entire judgment or only a disputed portion?
• Did a written settlement limit its effect?

F. Effect on lien

Even where acknowledgment restarts the judgment limitation:

• The existing lien’s separate ten-year term does not automatically restart.
• Original priority is not automatically preserved.
• A new judgment ordinarily needs new docketing or transcript filing.
• The new lien’s priority begins under the applicable filing rule.

No contrary extension mechanism was verified.

VII. Judgment-lien architecture

A. District Court judgment in original county

Once docketed, a District Court judgment becomes a lien on the debtor’s:

• Nonexempt real property.
• In that county.
• Owned at docketing or acquired while the lien remains alive.

The lien lasts ten years unless the judgment is sooner satisfied. Montana Code Annotated

B. Another Montana county

A certified transcript of the original docket must be filed with the District Court clerk of the other county. The lien begins there on filing but expires ten years from original judgment entry. Montana Code Annotated

Thus, a transcript filed eight years after judgment does not ordinarily create a fresh ten-year lien. It creates, at most, the remaining part of the original ten-year lien period.

C. Justice Court and Small Claims

A Justice Court judgment creates a real-property lien only upon filing a certified transcript with the District Court clerk in the county where the land is situated. The statute says the lien continues ten years unless sooner satisfied. Montana Code Annotated

The lien provision does not itself extend the underlying judgment-enforcement period. A transcript filed late cannot be assumed to revive an expired judgment.

Small Claims operates as a Justice Court division, but the precise current Small Claims transcript and satisfaction forms were not readable through the public source route.

D. Federal Montana judgment

A certified transcript of a qualifying Ninth Circuit or District of Montana judgment may be filed with any Montana county’s District Court clerk. The lien then attaches to nonexempt real property in that county and continues ten years unless satisfied. Montana Code Annotated

Federal §1962 likewise makes a federal District Court judgment lien conform to the manner, extent, conditions, and duration of a state general-jurisdiction judgment. U.S. Code

E. No automatic statewide lien

Montana does not make one District Court docket entry an automatic lien on all real estate statewide. Each additional county requires the applicable transcript filing.

F. Property and enforcement limits

A judgment lien under these provisions is:

• A lien on nonexempt real property.
• Not an automatic lien on wages.
• Not an automatic levy on a bank account.
• Not a seizure order.
• Not authority to bypass homestead or other exemptions.
• Not, by itself, a foreclosure judgment.

Full exemptions, execution, levy, foreclosure of liens, garnishment, and priority contests remain separate.

G. New judgment and lien priority

A new judgment obtained through an action on the old judgment may support a new lien once docketed or transcribed. The new lien does not automatically inherit the priority date of the old lien. Priority and intervening interests remain outside this component.

VIII. Lien matrix

IX. Sister-state judgments

A. Registration

An authenticated sister-state judgment may be filed with a Montana District Court clerk. Once filed, it is treated like a Montana District Court judgment and is subject to the same procedures, defenses, reopening, vacatur, stay, enforcement, and satisfaction rules. Montana Code Annotated

B. Affidavit and notice

At filing, the creditor or attorney must file an affidavit stating:

• Debtor and creditor names and last-known addresses.
• That the judgment is valid and enforceable.
• The extent to which it has been satisfied.

The creditor must mail certified notice, return receipt requested, with copies of the judgment and affidavit, and file an affidavit stating the mailing date. Execution proceeds cannot be distributed to the creditor before 30 days after mailing. Montana Code Annotated

C. Stay

If appeal or a stay is pending in the rendering state, Montana must stay enforcement upon the required showing and security. Montana also applies its ordinary stay grounds with corresponding security. Montana Code Annotated

D. Duration

Oskerson holds that Montana’s ten-year enforcement period applies, but it runs from original judgment entry. Montana registration does not create a new ten-year period. Justia Law+1

X. Satisfaction and release

A. Statutory routes

Satisfaction may be entered through:

1. An execution returned satisfied.
2. A filed acknowledgment of satisfaction by the creditor, acknowledged like a real-property conveyance.
3. The creditor’s endorsement on the judgment record.
4. The creditor’s attorney’s acknowledgment or endorsement, unless the attorney’s authority has been revoked in the record.
5. A court order compelling acknowledgment.
6. A court order directing entry without the creditor’s acknowledgment. Montana Code Annotated

B. Mandatory acknowledgment after payment outside execution

When the judgment is satisfied in fact otherwise than through execution, the party or attorney shall give the acknowledgment or endorsement. The statute does not condition that duty on creditor convenience.

C. Partial satisfaction

Gullett holds that §25-9-311 permits and may compel partial as well as total satisfaction. Payment of one adjudicated component does not have to remain invisible merely because attorney fees, costs, interest, or another amount remains unresolved. Justia Law

D. Allocation

Shilhanek rejected automatic application of the general contract-allocation statute to a debtor’s proposed characterization of a judgment payment. The judgment, payment terms, available coverage, and court’s equitable and procedural authority can control. Justia Law

Accordingly, a payment is not automatically allocated:

• To principal first.
• To interest first.
• To punitive damages.
• To attorney fees.
• To one of several judgments.

The actual judgment, designation, acceptance, governing order, and applicable law must be read.

E. Full satisfaction

A full satisfaction generally requires resolution of all then-due components, including:

• Judgment principal.
• Lawful accrued postjudgment interest.
• Awarded costs.
• Awarded attorney fees where part of the judgment.
• Other adjudicated amounts.

Warrington confirms that principal payment without accrued postjudgment interest was not full satisfaction. Justia Law

F. Creditor unavailable or refuses

The debtor or other interested party may move the court to:

• Compel acknowledgment or endorsement.
• Order satisfaction entered without it.

Evidence may include:

• Judgment.
• Payment records.
• Cleared funds.
• Settlement.
• Release.
• Interest calculation.
• Costs and credits.
• Prior partial satisfactions.
• Notice to the creditor or attorney.
• Proof of authority.

No actual motion or form is supplied here.

G. No express deadline or penalty in §25-9-311

The section states a mandatory acknowledgment duty but contains no fixed ten-day, thirty-day, or other deadline. It also states no standalone civil penalty, damages formula, or automatic attorney-fee award for refusal.

That does not foreclose another claim under different law; it means such relief cannot be attributed to §25-9-311 without additional authority.

H. Cross-county records

A judgment may have:

• Original-county docket lien.
• Transcripts in other counties.
• Federal or sister-state registrations.
• Partial satisfactions.
• A replacement judgment.

The reviewed Montana satisfaction statute does not describe an automatic statewide electronic propagation mechanism. A party relying on satisfaction to clear multiple county records must verify each relevant docket or recording office. No county-specific filing step is invented here.

I. Distinct legal events

XI. Official forms and resources

A blank form does not establish:

• Full payment.
• Interest accuracy.
• Signer authority.
• Satisfaction in all counties.
• Release of unrelated liens.
• Credit-report deletion.

XII. Federal and state distinctions

A. Federal interest

For a federal District Court civil money judgment:

r=weekly average 1-year constant maturity Treasury yield for preceding calendar weekr=\text{weekly average 1-year constant maturity Treasury yield for preceding calendar week}r=weekly average 1-year constant maturity Treasury yield for preceding calendar weekInterest:

• Begins on judgment entry.
• Is computed daily.
• Is compounded annually. U.S. Code

This differs from Montana’s state default rule:

B. Federal lien in Montana

Federal §1962 makes a federal District Court judgment a lien only in the same manner and under the same conditions as a state general-jurisdiction judgment. Montana provides the transcript-filing route in §25-9-303. U.S. Code+1

C. Registration in another federal district

A qualifying federal money or property judgment may be registered in another federal district when final by appeal or lapse of appeal time, or earlier for good cause shown. The registered judgment has the same effect as one entered in that district. A certified full or partial satisfaction may likewise be registered where the judgment is a lien. U.S. Code

XIII. Bounded hypothetical workflows

These examples are arithmetic and procedure demonstrations only. They are not collection quotes, payoff statements, title opinions, or permission to enforce.

Example 1 — Ordinary Montana 2026 statutory-rate judgment

Assumptions

• Montana state judgment entered in 2026.
• Current statutory branch applies.
• No specified contract rate.
• Interest-bearing judgment base: $10,000.00.
• Exactly one year elapses.
• No payments or credits.

Rate:

6.75%+3.00%=9.75%6.75%+3.00%=9.75%6.75%+3.00%=9.75%Interest:

$10,000.00×0.0975×1=$975.00$10,000.00\times0.0975\times1

$975.00$10,000.00×0.0975×1=$975.00Hypothetical total after exactly one year:

$10,000.00+$975.00=$10,975.00$10,000.00+$975.00

\boxed{$10,975.00}$10,000.00+$975.00=$10,975.00​No compounding is added. Montana Code Annotated+1

Example 2 — Historical proceeding before July 1, 2017

Assumptions

• Proceeding began June 1, 2017.
• Judgment entered later.
• No specified contract rate.

Because the 2017 amendment was inapplicable to proceedings begun before July 1, 2017, the current prime-plus-three formula is not automatically used. The exact rate requires the prior statutory version and case chronology.

Result: terminal amount held; no 9.75% calculation. Justia Law

Example 3 — Contract-rate branch

Assumptions

• Valid judgment involving a contractual obligation.
• Contract proved to specify 12.00% postjudgment interest.
• $8,000.00 interest-bearing amount.
• Exactly one year.
• No compounding clause assumed.

$8,000.00×0.12=$960.00$8,000.00\times0.12

$960.00$8,000.00×0.12=$960.00$8,000.00+$960.00=$8,960.00$8,000.00+$960.00

\boxed{$8,960.00}$8,000.00+$960.00=$8,960.00​This does not establish that the contract rate is lawful, applies after judgment, or authorizes compounding.

Example 4 — Partial payment and conditional allocation

Assumptions

• $5,000.00 judgment.
• 9.75% simple.
• Exactly one year has accrued before payment.
• Payment: $1,000.00.
• A valid judgment term, agreement, or court order allocates accrued interest first.

Accrued interest:

$5,000.00×0.0975=$487.50$5,000.00\times0.0975

$487.50$5,000.00×0.0975=$487.50Payment remaining after interest:

$1,000.00−$487.50=$512.50$1,000.00-$487.50

$512.50$1,000.00−$487.50=$512.50Remaining principal:

$5,000.00−$512.50=$4,487.50$5,000.00-$512.50

\boxed{$4,487.50}$5,000.00−$512.50=$4,487.50​Held branch: Without a valid interest-first rule, this allocation is not assumed. Shilhanek warns against mechanically importing ordinary contract-allocation rules into judgment allocation. Justia Law

Example 5 — No action or execution before the ten-year period ends

Assumptions

• Ordinary court-of-record judgment entered January 15, 2017.
• No qualifying acknowledgment, new judgment, statutory suspension, or special-sector rule.
• No action on judgment filed.
• No execution issued before the period ended.

Ordinary ten-year endpoint:

January 15, 2017+10 years=January 15, 2027\text{January 15, 2017}+10\text{ years}

\text{January 15, 2027}January 15, 2017+10 years=January 15, 2027After that point, ordinary action and execution are time-barred absent a legally valid restart or other exception. A demand letter or later assignment does not itself create a new judgment. Montana Code Annotated+1

Example 6 — Signed acknowledgment versus unexplained payment

Branch A — signed acknowledgment

• Judgment entered in 2018.
• In 2024, before expiration, debtor signs a writing clearly identifying the unsatisfied judgment and acknowledging the balance.

Under §27-2-409 and Brown/Dodd, the ten-year judgment limitation can begin anew from the acknowledgment.

Branch B — unexplained $100 payment

• Creditor ledger shows $100.
• No payer identity.
• No proof it was applied to principal or interest on this judgment.
• No signed acknowledgment.

No restart is established from those facts alone.

Branch C — payment after the original ten years

The effect remains held. The reviewed judgment cases did not establish a universal post-expiration revival-by-payment rule.

Example 7 — Timely action on judgment

Assumptions

• Original judgment entered January 15, 2017.
• Creditor files a separate action on December 1, 2026.
• Plaintiff proves current ownership and unsatisfied amount.
• Valid service and defenses are resolved.
• New judgment entered March 1, 2027.

The filing occurs before the ordinary ten-year period expires. The new judgment can begin a new ten-year judgment period.

It is not:

• An ex parte extension.
• An automatic continuation of the old lien’s priority.
• Proof that all prior interest was lawfully capitalized.

A new lien requires the new judgment to be docketed or transcribed. Justia Law

Example 8 — Original county versus another county

Assumptions

• District judgment entered and docketed in County A on February 1, 2026.
• Certified transcript filed in County B on August 1, 2028.
• No satisfaction.

County A lien:

February 1, 2026 through February 1, 2036\text{February 1, 2026 through February 1, 2036}February 1, 2026 through February 1, 2036County B lien:

• Begins August 1, 2028.
• Ends February 1, 2036.

It does not run through August 1, 2038 because the other-county statute measures from original judgment entry. Montana Code Annotated+1

Example 9 — Justice or Small Claims judgment and real estate

Assumptions

• $4,000.00 Justice Court judgment.
• Debtor owns nonexempt real property.
• No transcript has been filed with District Court.

Before transcript: no §25-31-914 real-property lien.

After certified transcript is filed in the county’s District Court: lien attaches to the debtor’s nonexempt real property in that county, subject to the statute’s ten-year language and the underlying judgment’s enforceability. Montana Code Annotated

Example 10 — Full payment but no satisfaction entry

Assumptions

• Principal: $10,000.00.
• Accrued interest: $975.00.
• Adjudicated costs: $200.00.
• All are paid.

Total paid:

$10,000.00+$975.00+$200.00=$11,175.00$10,000.00+$975.00+$200.00

\boxed{$11,175.00}$10,000.00+$975.00+$200.00=$11,175.00​Creditor or authorized attorney must acknowledge satisfaction when payment occurred outside execution. If the creditor refuses or is unavailable, a motion may ask the court to compel acknowledgment or order satisfaction entered.

This does not automatically update every other county or delete a credit report. Montana Code Annotated

Example 11 — Partial satisfaction

Assumptions

• Total judgment then due: $10,000.00.
• Valid payment credited: $4,000.00.
• Remaining amount before later interest: $6,000.00.

A partial satisfaction can be entered or compelled for the $4,000.00.

It would be incorrect to enter full satisfaction unless every remaining component is resolved. Justia Law

Example 12 — Sister-state judgment

Assumptions

• Original judgment entered June 1, 2020.
• Properly filed in Montana June 1, 2025.
• No restart or special exception.

Montana enforcement endpoint:

June 1, 2020+10 years=June 1, 2030\text{June 1, 2020}+10\text{ years}

\text{June 1, 2030}June 1, 2020+10 years=June 1, 2030The 2025 registration does not create a 2035 endpoint. Justia Law

Example 13 — State versus federal judgment

Montana state judgment entered in 2026

• Default rate: 9.75% simple.
• Fixed based on 2026 entry year.

Federal District Court judgment

• Rate: preceding calendar week’s one-year Treasury yield.
• Computed daily.
• Compounded annually.

No exact federal rate is calculated without the federal judgment date. U.S. Code

Example 14 — Private arbitration award

Facts

• Arbitrator issues a $7,500.00 award.
• No court confirmation or judgment has been entered.

Result

• No Montana court judgment yet.
• No District Court judgment lien.
• No execution writ based solely on §27-5-314.
• No ordinary state judgment interest conclusion from this pass.

After a court enters judgment conforming to a confirmation/modification/correction order, the judgment may be docketed and enforced like another judgment. Montana Code Annotated

XIV. Source register

XV. Claim register

XVI. Coverage and remaining-gap table

XVII. Researcher self-check

Freshly read on October 26, 2026

• Montana statutes governing:Judgment interest and contract-rate exception.Prejudgment-interest gateways.Ten-year action on judgment.Ten-year execution period.Action commencement and current service conflict.Docketed judgment liens.Other-county liens.Justice Court liens.Federal Montana judgment liens.Satisfaction entry.Sister-state filing, notice, stay, and enforcement.Judgment on confirmed arbitration award.
• Federal Reserve H.15/FRED prime-rate series through September 2026.
• Federal statutes governing:Federal postjudgment interest.Federal judgment liens.Interdistrict judgment and satisfaction registration.
• Full public reproductions of the material Montana Supreme Court opinions identified above.
• Official Montana satisfaction-form and civil-resource pages.
• The one-page District Satisfaction of Judgment PDF was visually inspected.

Numerical checks

• 2026 Montana rate:6.75% + 3.00% = 9.75%.
• One-year interest on $10,000:$10,000 × .0975 = $975.
• Contract example:$8,000 × .12 = $960.
• Partial-payment example:$5,000 × .0975 = $487.50.$1,000 − $487.50 = $512.50.$5,000 − $512.50 = $4,487.50.
• Full-payment example:$10,000 + $975 + $200 = $11,175.
• Other-county lien example:Original judgment February 1, 2026.Transcript August 1, 2028.Expiration remains February 1, 2036.

Access-limited or failed sources

• Justice/City satisfaction form was linked officially but its .doc contents could not be read.
• Small Claims satisfaction form was linked officially but its .docx contents could not be read.
• Several Montana opinions were read from full public reproductions rather than official court-hosted PDFs.
• No paid citator, title database, county clerk index, or private docket was used.

Bounded negative results and unresolved questions

No current controlling public authority located in this pass conclusively establishes:

• Automatic annual repricing of Montana judgment interest.
• Statutory compounding under the default state branch.
• Automatic compounding under every contract-rate branch.
• A separate routine “dormancy revival” motion.
• Automatic judgment renewal through execution, demand, assignment, or transcript filing.
• Automatic restart of every judgment from a partial payment.
• Post-expiration revival of every ordinary judgment by acknowledgment or payment.
• Automatic extension of the old judgment lien after acknowledgment or new action.
• Automatic preservation of old lien priority.
• Automatic statewide judgment lien.
• Automatic cross-county propagation of satisfaction.
• A fixed statutory deadline or penalty in §25-9-311 for failing to acknowledge satisfaction.
• Automatic credit-report deletion after satisfaction.
• One exact City or Municipal Court real-property-lien transcription route.
• A universal state form for partial satisfaction.

Search limits are not treated as proof that no unpublished order, county practice, special-sector statute, contract term, or later authority exists.

Not read or resolved

• Any actual:Judgment.Verdict.Contract.Interest clause.Rate history.Payment.Ledger.Assignment.Transcript.County docket.Property record.Satisfaction.Settlement.Appeal.Stay.Bankruptcy.Title record.
• Any named debtor, creditor, debt buyer, servicer, provider, arbitrator, or court case.
• Full execution, levy, garnishment, exemptions, homestead, lien foreclosure, priority, postjudgment discovery, bankruptcy, probate, secured-debt, sector, local, or tribal analysis.
• PASS-17 as an accepted legal premise.

Exact individual fetch timestamps were not exposed and are not invented. No payoff statement, title search, filing, revival action, transcript filing, satisfaction, release, calculation for an actual judgment, provider lookup, docket access, contact, record request, purchase, account change, private-data access, browser control, other-chat access, local write, collection approval, judgment approval, independent review, component acceptance, Montana acceptance, parent-dossier acceptance, A066 acceptance, operational approval, or publication-readiness determination occurred.

REPORT PARTIAL — the focused Montana ordinary consumer-debt judgment-interest, enforceable-duration, action-on-judgment, judgment-lien, satisfaction, and federal/state-boundary component is completed to the stated statutory, factual, source, and currentness limits.

END S_MT PASS-18.