Payment in satisfaction of a money judgment, including payment of a severable portion of the money judgment, interest thereon, and associated costs, does not constitute a waiver of the right to appeal, except to the extent that the payment is the product of compromise or is coupled with an agreement not to appeal. Payment in satisfaction of a severable portion of a money judgment, interest thereon, and associated costs, does not constitute a waiver of the right to appeal other portions of the money judgment.
§ 695.215.Effect of Payment to Satisfy Judgment
Title 9. Enforcement of Judgments · Division 2 · Chapter 1. General Provisions · Article 2. Amount to Satisfy Money Judgment · Enacted 2019 · no amendments on record · Last verified July 28, 2026
In one sentenceSection 695.215 protects a party's right to appeal despite paying a money judgment -- including a severable portion of it -- unless the payment resulted from a compromise or came bundled with an agreement not to appeal, and it shields the right to appeal remaining portions of a judgment even after a severable part has been paid.
Full Text of § 695.215
Plain-English Summary
Paying a judgment might look like giving up the fight, but § 695.215 says it usually isn't. Paying a money judgment -- even just a severable portion of it, along with interest and costs on that portion -- doesn't waive the right to appeal, unless the payment was the product of a compromise or came coupled with an agreement not to appeal.
The second sentence extends that protection to piecemeal payments. Paying off one severable part of a judgment doesn't waive the right to appeal the other, unpaid parts. A party can satisfy the portion it doesn't intend to contest while still preserving a challenge to the rest.
This matters for litigants weighing whether to pay now and appeal later, or to hold off entirely to preserve appellate rights. Section 695.215 removes one common worry -- that voluntary payment itself, without more, forfeits appellate review.
Frequently Asked Questions
Does paying a judgment waive the right to appeal it?
Not by itself. Section 695.215 preserves the right to appeal unless the payment was the product of a compromise or coupled with an agreement not to appeal.
Can I pay part of a judgment and still appeal the rest?
Yes. Section 695.215 says paying a severable portion of a judgment does not waive the right to appeal the remaining portions.
What would cause payment to waive appeal rights?
Only if the payment is the product of a compromise, or is coupled with an agreement not to appeal.
Amendment History
Added by Stats 2019 ch 48 (AB 1361),s 1, eff. 1/1/2020.
Source & verification. Section text is reproduced verbatim from
the Deering's California Codes Annotated / vLex. Enacted by the California Legislature.
Last verified July 28, 2026.
· Official source
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