Judgments are not eternal. Creditors must keep in mind that a judgment against a debtor may not be enforced after a certain number of years as determined by a state's statute.

In Virginia, a judgment recorded in the books of a county's circuit court is enforceable for 20 years. In D.C., a judgment recorded in the office of the Recorder of Deeds is enforceable for 12 years from the date when the judgment became enforceable.

When trying to enforce a judgment from another state, those periods can vary depending on the new jurisdiction. The D.C. Court of Appeals recently provided more clarity to the District's own statute of limitation on the enforcement of foreign judgments.

In a case involving the enforcement of a 2001 California judgment in Washington, D.C., the Court of Appeals ruled that the statute of limitations to enforce the California judgment did not begin to run until the judgment was filed the Superior Court in November 2006.

This decision brings the District in line with a large number of states, including Maryland, that have ruled that the filing of a foreign judgment triggers a new limitation period. 

The case is Czajka v. Holt Graphic Arts, Inc., Case No. 18-CV-1257 & 19-CV-64, and was issued on November 23, 2022.