The judgment may be enforced in the same manner as if it had been rendered in an action of the same jurisdictional classification in the same court, and is in the same manner subject to appeal.
§ 1140.Enforcement of Judgment
Title 3. Of Summary Proceedings · Chapter 2. Submitting a Controversy Without Action · Last amended 1998 · Last verified July 29, 2026
In one sentenceSection 1140 provides that a judgment entered on a submitted controversy is enforced the same way as a judgment rendered in an ordinary action of the same jurisdictional classification in the same court, and remains equally subject to appeal.
Full Text of § 1140
Plain-English Summary
A judgment reached through § 1138's shortcut carries the same weight as any other. Section 1140 makes that explicit: enforcement works the same way it would for a judgment entered in an ordinary action of the same jurisdictional classification, in the same court.
The "same jurisdictional classification" language matters because California courts distinguish limited and unlimited civil cases for enforcement and appellate purposes. A submitted controversy that would have been a limited civil case, had it been filed as one, is enforced and appealed the way a limited civil judgment is; the same holds for an unlimited case.
Appeal rights survive the shortcut too. Nothing about skipping a full lawsuit under § 1138 narrows either side's right to appeal the resulting judgment — it's treated as if the case had gone the ordinary route from complaint to trial.
Frequently Asked Questions
How is a judgment on a submitted controversy enforced?
The same way as a judgment entered in an ordinary action of the same jurisdictional classification, in the same court.
Can either party appeal a judgment reached through submission without action?
Yes. Section 1140 makes the judgment subject to appeal in the same manner as any other judgment.
Does it matter whether the case would have been a limited or unlimited civil case?
Yes. Section 1140 ties enforcement to the jurisdictional classification the action would have carried, so limited and unlimited cases are enforced under their own respective procedures.
Amendment History
Amended by Stats. 1998, Ch. 931, Sec. 115. Effective September 28, 1998.
Source & verification. Section text is reproduced verbatim from
the Deering's California Codes Annotated / vLex. Enacted by the California Legislature.
Last verified July 29, 2026.
· Official source
Also known as: enforcing judgment submitted controversy californiaappeal submission without action california