Short answer. Yes. On your demand as judgment obligor, the judgment obligee or counsel must execute, acknowledge, or endorse an admission of satisfaction. If they refuse, after notice and a motion, the court may order them to do so, or simply order the entry of satisfaction made without their admission.

What the law says

Whenever a judgment is satisfied in fact, or otherwise than upon an execution, on demand of the judgment obligor, the judgment obligee or his counsel must execute and acknowledge, or indorse, an admission of the satisfaction as provided in the last preceding section, and after notice and upon motion the court may order either the judgment obligee or his counsel to do so, or may order the entry of satisfaction to be made without such admission.

Rule 39, Section 45 — Entry of satisfaction with or without admission. Read the full provision →

Satisfaction outside of execution

This section applies whenever a judgment has been satisfied in fact, or in some way other than through the formal process of execution described elsewhere in the Rule, such as a direct payment or settlement between the parties themselves that never went through the sheriff. Because no writ was ever returned to document that payment, the obligor needs a separate mechanism to get the satisfaction formally reflected on the court record. A common example is when the obligee accepts payment directly from the obligor, or the parties reach a compromise, without ever going back to the sheriff to have a writ formally returned as satisfied; in either case the court record would otherwise still show the judgment as unpaid unless the obligor takes the additional step this section provides for.

The obligor's demand triggers a duty

On the demand of the judgment obligor, the judgment obligee, or his counsel, is required to execute and acknowledge, or endorse, an admission of that satisfaction, following the same process laid out in the preceding section of the Rule for how such admissions are made. The obligee cannot simply ignore a proper demand once the judgment has genuinely been satisfied outside of the execution process.

If the obligee will not cooperate, the court's fallback options

Should the obligee or counsel fail to comply with that demand, the judgment obligor may, after notice and upon motion, ask the court to order the obligee or counsel to make the admission after all, or the court may simply order the entry of satisfaction to be made in the record without requiring any admission from the obligee at all. This fallback matters because an obligee who has, in fact, already been paid should not be able to block the record from reflecting that fact simply by refusing to sign anything, and the court's authority to order entry of satisfaction without an admission closes off that possibility.

Related provisions

Note. Statute text quoted on this page is reproduced from the official enactment and is linked to the full provision. The explanation around it is general legal information from Vivas & Nobles Law Office, not legal advice. Whether it applies to your situation depends on facts only a lawyer reviewing them can assess.