How to Collect a Judgment From a Business: Levies and Liens

The Notice of Entry of Judgment that a California small claims clerk mails out has a second form traveling with it, addressed to the party who lost. It is the Judgment Debtor's Statement of Assets, form SC-133, and it asks where the business banks, who owes it money, and what it owns. The debtor has 30 days to fill it in and send it to you, unless it has paid by then (CCP 116.830).

A debtor that has not paid usually does not send that form either, and that says a lot about the stage you have reached. At the hearing somebody else ran the process. From here the court stamps what you bring to it, and the Orange County Superior Court's collections page says so in two short sentences: you have to take legal steps to collect the judgment, and the court will not collect it for you.

This page covers how to collect a judgment from a business, the usual debtor for a freelancer, in four states: California, New York, Texas and Illinois. Washington, Michigan and Florida, which appear on the small claims filing page, are not covered here.

I am not a lawyer and none of this is legal advice. Every statute and court page below was read on 19 September 2026. Where a figure comes from a court's guidance rather than a statute, the sentence says so.

The month you cannot enforce, and what to do with it

Every state gives the loser a window to appeal or to ask for the judgment to be set aside, and enforcement waits for it. California suspends enforcement of a small claims judgment automatically, including the issuing or recording of an abstract of judgment, until the time for appeal expires (CCP 116.810). The Orange County page translates that into a date: no action for 30 days from the day the clerk mailed the Notice of Entry of Judgment (form SC-130).

Texas runs a clock of the same length from a different paper. Under Rule 627 of the Texas Rules of Civil Procedure, execution issues on application after 30 days from the day the final judgment is signed. Rule 628 allows it sooner only on an affidavit that the defendant is about to move its property out of the county or hide it to defraud creditors. That affidavit is sworn, and it should be true.

In New York City the Sheriff's Office will take a small claims judgment for collection once the defendant has not paid within 30 days (NYC Department of Finance, Sheriff).

Use that month. Every tool that follows needs an address: a bank, a street where the business trades, a customer who owes it money, a county where it owns land. A levy with no target is a fee paid for a return marked "nothing found".

Where a business client keeps its money, and how you probably already know

Start with your own records. If this client ever paid you anything, a deposit or an earlier invoice, the money came from an account. A cheque carries the bank's name and routing number on its face. An ACH credit says less, but your own bank's record of the transfer, or a remittance advice from a vendor portal, sometimes names the paying bank. Ask your bank what its record shows.

Then think about who pays the client. A studio that owed you $4,800 is almost certainly owed money by its own customers, and those receivables can be reached. After that come equipment and vehicles.

When your records run out, each state has a way of making the debtor, or people who know about it, answer questions.

• California. If the SC-133 does not arrive, file form SC-134, an order for the debtor to produce the statement and appear for examination. The order must be personally served at least 30 days before the examination, and serving it creates a lien on the debtor's personal property for one year (CCP 708.110). Nobody has to attend an examination in another county 150 miles or more from where they live or do business (CCP 708.160), so for a distant client the examination moves to the client's court. A willful failure to return the form can bring contempt sanctions, including arrest and attorney's fees (116.830(d)).
• New York. The small claims clerk must, on request, issue information subpoenas at nominal cost and help you prepare them (CCA 1812(d)). A subpoena sent to anyone other than the debtor, a bank for instance, has to carry a signed certification that you have a reasonable belief the recipient holds information that will help you collect. Without it the subpoena is null and void (CPLR 5224).
• Texas. The justice court rules allow written post-judgment discovery without first asking the court, and the debtor gets at least 30 days to answer (Rule 500.9). The justice court clerk can tell you how an objection is handled.
• Illinois. The tool is a citation to discover assets, issued by the clerk, which can be served on the debtor or on any other person to examine them about the debtor's assets and to compel non-exempt assets toward the judgment (735 ILCS 5/2-1402). The notice on its face warns in capitals that a person who fails to appear may be arrested.

An LLC gets none of the protections a person does

Most of the protective language in this area was written for individuals, and it is easy to read a debtor-rights notice and assume your client is covered. A business usually is not. California says it in one sentence: the exemptions in its enforcement chapter apply only to the property of a natural person (CCP 703.020). New York's limit of two restraining notices a year on a bank account applies to a natural person's account (CPLR 5222(c)).

The other side matters as much. The judgment reaches the party it names and nobody else. If you sued "Brightline Media" and it is really one person trading under that name as a sole proprietor, California lets you ask the court, on form SC-105, to add the owner's personal name. If Brightline Media is a real LLC, the Orange County page is blunt: you will not be able to have the judgment changed to name an officer or employee of the business. A single-member LLC with an empty account can be a perfect judgment debtor and pay nothing. Reaching its owner is a different lawsuit on a different theory, and not one to start from a self-help page.

That is why the collections ladder ends with whether there is anything there to collect.

A bank levy catches one day's balance

In California you ask the clerk for a writ of execution (form EJ-130), which costs $40 (Government Code 70626), and give it to the sheriff with instructions naming the bank. The sheriff's fee for serving or executing process is set at $50 (Government Code 26720.9), though the office will tell you what a particular levy costs.

The detail that decides whether it works is in CCP 700.140(b): the lien reaches only what is in the account when the bank is served. Tomorrow's deposits are not caught. A client that sweeps its operating account every Friday can be levied on Thursday and yield nothing. If you know its rhythm, when its customers pay and when it runs payroll, put that in the instructions.

New York does it in two stages. A restraining notice, which the clerk can issue, freezes what the person served holds for the debtor for one year or until the judgment is satisfied, and a bank that holds back twice the amount due has done what the notice requires (CPLR 5222(b)). The money is then taken under an execution delivered to a sheriff or, inside the city, a city marshal. The New York City Sheriff charges $35 for a small claims execution, sent with a Request for an Execution and a Creditor's Advisory to its office in the county where the debtor is located. The same page adds a trap: a small claims judgment from a court outside New York City is not valid there unless it is docketed in a New York State Supreme Court.

Texas uses garnishment. With a valid judgment, a writ of garnishment is available on your affidavit that, within your knowledge, the defendant does not have property in Texas subject to execution sufficient to satisfy it (Civil Practice and Remedies Code 63.001), and a justice of the peace can issue it (63.002). It is a proceeding against the bank as garnishee, and the justice court clerk is the person to ask for the local form.

Illinois can do it inside the citation: served on a bank as a third party, it brings the account into the proceeding, and the court can order non-exempt funds applied to the judgment (2-1402).

Till taps, keepers and turnover orders

For a client that takes payments at a counter, such as a café that commissioned a menu redesign, California has a tool aimed at the cash. The Solano County Superior Court's enforcement page describes both versions. A till tap sends the sheriff in to take all cash and checks out of the register. A keeper's levy stations the sheriff at the business for 8 to 12 hours to collect money as it is paid in.

During a keeper's levy the business can keep trading as long as every sale is final and for cash or its equivalent, a cheque counting as cash, and the keeper takes custody of the proceeds (CCP 700.070). It is not cheap: the keeper's fee is $175 for each eight-hour period or part of one (Government Code 26726), and Solano's page names the obvious risk, that the debtor closes for the day and the sheriff collects nothing. On a $4,800 judgment one keeper day is worth trying once, not three times.

Texas reaches the same kind of asset by court order. A judgment creditor is entitled to help from a court, and the statute names the justice court specifically, to reach non-exempt property. The court can order the debtor to turn property over to a sheriff or constable, apply it to the judgment, or appoint a receiver, and it enforces those orders by contempt (Civil Practice and Remedies Code 31.002). You can ask in the same case that produced the judgment, and the creditor is entitled to recover reasonable costs, including attorney's fees (31.002(e)). A plain writ of execution to a sheriff or constable remains the default, returnable in 30, 60 or 90 days as you choose (Rule 629).

Liens: the slow tools that wait for a sale

A lien does not pay you this month. It sits on the record until the debtor tries to sell, refinance or borrow, and then it has to be dealt with.

• California, real property. Recording an abstract of judgment with a county recorder creates a lien on the debtor's real property in that county, lasting 10 years from entry of the judgment (CCP 697.310). The clerk charges $40 to issue the abstract (Gov. Code 70626(a)(2)); the recorder charges separately.
• California, business assets. A notice of judgment lien (form JL1) filed with the Secretary of State creates a lien on the debtor's accounts receivable, equipment, inventory and certain other personal property, and it attaches to property the debtor acquires later (CCP 697.530). It lasts five years and can be continued by a filing made in the six months before it lapses (CCP 697.510). The Secretary of State says the form must reach its office within ten days of the notice date. For a service business whose main asset is money owed to it by its clients, this is the lien that touches something real.
• New York. The small claims clerk issues a transcript of judgment, which you file with the County Clerk where the debtor owns property; docketing it there protects you against transfers of the debtor's real property in that county for ten years (CPLR 5203).
• Texas. An abstract of judgment issued by the justice court and recorded with the county clerk is a lien on the debtor's non-exempt real property in that county, including property acquired later (Property Code 52.001). It lasts 10 years from recording, but ends early if the judgment itself goes dormant (52.006).
• Illinois. A judgment becomes a lien on real estate in a county only from the time a transcript, certified copy or memorandum of it is filed with that county's recorder (735 ILCS 5/12-101).

New York's lever for clients who make a habit of it

One New York provision is aimed squarely at businesses that treat small claims judgments as optional. Under CCA 1812, you may sue for three times the unpaid judgment, plus reasonable counsel fees and costs, when three things are true: your judgment came from a transaction in the course of the debtor's trade or business (or a repeated course of dealing), there are at least two other unpaid recorded small claims judgments against the same debtor arising from it, and the debtor failed to pay yours within 30 days of receiving notice of it.

Two conditions narrow it. The notice has to be served like a summons or sent by certified mail, return receipt requested, and has to state that the judgment exists, that at least two other unpaid recorded judgments exist, and that failure to pay may lead to an action for treble the amount. And the debtor has a defense if it did not have the resources to pay within those 30 days. A client that is simply broke is not the target; one that pays nobody until forced is.

You find out whether the other judgments exist from the court. Section 1811(d) requires unpaid small claims judgments to be indexed alphabetically and chronologically under the debtor's name, so the clerk can tell you whether your debtor is already listed. If you then win the treble-damages judgment against a business, the court must advise the Attorney General and, for a licensed or certified business, the licensing authority as well (1812(c)).

How long the judgment lives, and what it earns meanwhile

A judgment expires if ignored, and it earns interest while it waits. Against a business, the rate is the general one in each state; the reduced rates are written for consumer debts owed by individuals.

Sources, all read on 19 September 2026: CCP 683.020, 683.110, 685.010; CPLR 211, 5004, 5014; CPRC chapter 34, Finance Code chapter 304; 735 ILCS 5/12-108 and 2-1303.

The Texas contract-rate line is the one place where something you wrote before the job changes the outcome after it: a late-payment rate in your contract carries into the judgment, up to 18%. Whether that clause was enforceable is its own question, covered in what late fees your state lets you charge. At California's 10%, a $4,800 judgment adds $480 a year, so a debtor who offers the original $4,800 two years later is asking you to give up about $960 of interest.

What each step costs, and which of it comes back

Each step is billed to you up front: the writ, the officer, the recording, the keeper. Most of it can be added back to what the debtor owes.

California gives the prevailing party in a small claims action the costs of enforcing the judgment and accrued interest (CCP 116.820(c)), limited to reasonable and necessary costs, with attorney's fees only where the underlying judgment awarded them (CCP 685.040). The mechanics are on the Solano page: costs are added by filing a Memorandum of Costs within two years of incurring them, interest can be added at any time, and the copy for the debtor must be mailed by someone other than you. Keep every receipt. A $40 writ and a $50 service fee, spent twice, is $180 that belongs on the debtor's side of the ledger.

New York has a cost that surprises people because it survives a deal. The sheriff is paid poundage, a percentage of what is collected: 5% in the New York City counties, and 5% on the first $250,000 elsewhere. If you settle after a levy, the sheriff is still entitled to poundage on the judgment or the settlement amount, whichever is less (CPLR 8012(b)). Before you accept the client's call offering half, work out that the officer's cut comes off your half.

The day the money arrives, one more form is yours to file

Once a judgment is paid, the duty to clear the record moves to you, and both large states attach a penalty to forgetting.

California requires the creditor to file an acknowledgment of satisfaction with the clerk immediately on full payment. A creditor who fails, without good cause, to file it within 14 days of the debtor's written demand is liable for the debtor's damages plus $50 (CCP 116.850). If you recorded an abstract anywhere, the Solano page notes that a different acknowledgment is needed, signed before a notary and recorded in every county where the abstract went.

New York gives you 20 days after full satisfaction. Miss it and the penalty is $100 on a judgment under $5,000, or $500 on one of $5,000 or more, and a copy of the satisfaction-piece has to be mailed to the debtor within ten days of filing (CPLR 5020).

File it the afternoon the money clears. A client that took eleven months to pay will not hesitate to collect $500 from you for filing on day twenty-one.