(a) If a judgment creditor intentionally conditions delivery of an acknowledgment of satisfaction of judgment upon the performance of any act or the payment of an amount in excess of that to which the judgment creditor is entitled under the judgment, the judgment creditor is liable to the judgment debtor for all damages sustained by reason of such action or two hundred fifty dollars ($250), whichever is the greater amount.
§ 724.070.Liability for Conditioning Delivery of Acknowledgment
Title 9. Enforcement of Judgments · Division 5 · Chapter 1. Satisfaction of Judgment · Enacted 1982 · no amendments on record · Last verified July 28, 2026
In one sentenceSection 724.070 makes a judgment creditor who intentionally conditions delivery of an acknowledgment of satisfaction on extra payment or performance liable for actual damages or $250, whichever is greater, unless the delivery was tied to a pre-satisfaction agreement for security or a promissory note not exceeding what the creditor is owed.
Full Text of § 724.070
(b) Subdivision (a) does not apply if the judgment creditor has agreed to deliver an acknowledgment of satisfaction of judgment to the judgment debtor prior to full satisfaction of the judgment in consideration for the judgment debtor's agreement either to furnish security or to execute a promissory note, or both, the principal amount of which does not exceed the amount to which the judgment creditor is entitled under the judgment.
Plain-English Summary
This section targets a specific kind of leverage a creditor might otherwise try to exercise: withholding the acknowledgment as a bargaining chip for something beyond what the judgment requires. If a creditor intentionally conditions delivering the acknowledgment on the debtor performing some act or paying an amount beyond the judgment entitlement, the creditor is liable to the debtor for whatever damages result, or $250, whichever amount is larger.
Subdivision (b) draws a careful exception for a legitimate arrangement: if the creditor has agreed to deliver the acknowledgment before full satisfaction in exchange for the debtor furnishing security, executing a promissory note, or both — so long as the note's principal doesn't exceed what the creditor is entitled to under the judgment — that bargained-for exchange isn't penalized under subdivision (a). The distinction is between a creditor extracting something extra through the leverage of withholding the acknowledgment, and a creditor and debtor voluntarily agreeing to an early acknowledgment secured by something no larger than the judgment debt itself.
Frequently Asked Questions
What triggers liability under § 724.070?
A judgment creditor intentionally conditioning delivery of the acknowledgment on the debtor performing an act or paying an amount beyond what the judgment entitles the creditor to.
How much can a creditor be liable for?
All damages sustained by the debtor because of that conduct, or $250, whichever amount is greater.
Is there ever a legitimate reason to delay delivering the acknowledgment?
Yes. Subdivision (b) exempts an agreement to deliver the acknowledgment before full satisfaction in exchange for security or a promissory note not exceeding the amount owed under the judgment.
Amendment History
Added by Stats. 1982, Ch. 1364, Sec. 2. Operative July 1, 1983, by Sec. 3 of Ch. 1364.
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
Also known as: wrongful withholding satisfaction of judgment californiapenalty for conditioning delivery of acknowledgment