Barrow v. Holmes

Date Filed: August 13, 2025 Case Number: A169131 Court: California Court of Appeal, First Appellate District, Division One The Court holds that a judgment creditor’s failure to file a claim in a decedent’s probate administration does not bar enforcement of a previously recorded judgment lien; the judgment against Martin Holmes remains valid and may be pursued against his property and successors. This decision affirms that a recorded abstract of judgment creates a lien enforceable under Code of Civil Procedure section 683-685 and Probate Code section 9391 without the prerequisite of a probate-court claim, thereby preserving creditors’ rights to collect judgments after a debtor’s death.