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Case No. A169131

The court held that a judgment creditor's failure to file a claim in the decedent's probate administration does not bar enforcement of a previously recorded judgment lien, so the judgment against Martin Holmes remains valid and may be pursued.

Case Brief Full Opinion

Date Filed: August 13, 2025
Case Name: Case No. A169131
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 §§ 683‑685 and Probate Code § 9391 without the prerequisite of a probate‑court claim, thereby preserving creditors’ rights to collect judgments after a debtor’s death.


This case summary was prepared for educational purposes. For the authoritative version, please refer to the full opinion or the official California Courts website.

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