Yes, you can claim every dollar a debtor owes you after judgment — but only if you fill out California Judicial Council Form MC-010 correctly and file it on time. The Memorandum of Costs After Judgment, Acknowledgment of Credit, and Declaration of Accrued Interest is the form a judgment creditor uses to add post-judgment costs, subtract payments received, and tally the running 10% interest the law lets them collect under California Code of Civil Procedure §685.010.
If you skip MC-010 or fudge the numbers, the court clerk will not add the costs to your judgment, the sheriff cannot levy the extra amount, and you forfeit money you legally earned. A 2024 report from the California Courts Self-Help Center noted that more than 60% of small-dollar civil judgments in California go uncollected, often because creditors never file the right post-judgment paperwork.
Here is what this guide covers:
- 📝 Line-by-line walkthrough of every box on Form MC-010 with plain-English meaning
- 💰 Worked interest math under the 10% statutory rate, with daily-rate examples
- 👥 Three named real-world scenarios showing how creditors actually use the form
- ⚖️ How a debtor fights back with a Motion to Tax Costs and the case law that controls it
- 🚫 Common mistakes, do’s and don’ts, and the exact filing windows that trip people up
What Form MC-010 Actually Is
Form MC-010 is the official Judicial Council of California form titled Memorandum of Costs After Judgment, Acknowledgment of Credit, and Declaration of Accrued Interest. It serves three jobs in one document. First, it adds new costs the creditor paid after the judgment, like sheriff fees and recording fees. Second, it records partial payments the debtor made so the running balance is honest. Third, it declares the interest that has piled up since the judgment was entered.
The form lives under Code of Civil Procedure §685.070, which lets the prevailing party add specific post-judgment costs without a separate motion. The plain-English meaning is simple. You won. You spent more money trying to collect. The law lets you bill the debtor for that extra cash, plus interest, as long as you list it on this form. The consequence of skipping the form is brutal. Costs not listed on a timely MC-010 are waived and can never be collected later, even if you spent the money.
A common misconception is that MC-010 covers attorney fees you spent during the original lawsuit. It does not. Original attorney fees go on Form MC-011 or are awarded inside the judgment itself. MC-010 only covers post-judgment enforcement costs. For a real-world example, imagine Maria Lopez won a $9,000 judgment last year. She paid $40 to record an Abstract of Judgment, $75 to the sheriff for a wage levy, and $15 for a writ of execution. Maria lists those three numbers on MC-010, signs it, and serves it on the debtor.
Who Files It and When
The judgment creditor — the winning party — files MC-010. A judgment debtor never files this form. The form can be filed any time within two years of paying the cost, under CCP §685.070(b), but most lawyers file it right before they ask the sheriff to levy or before the judgment is renewed.
The consequence of waiting too long is permanent loss of those dollars. The two-year clock is not flexible, and judges routinely strike late memoranda. A common misconception is that you can file one giant MC-010 at the end of collection covering every cost you ever spent. That is wrong, because the two-year window runs from each individual cost. David Chen, a small-business owner in San Diego, learned this when he tried to claim a $200 sheriff fee from 2022 on a 2025 memorandum and the court rejected it.
Where the Form Goes
You file the original at the same court that entered the judgment. You then serve a copy on the judgment debtor by mail, following the proof-of-service rules in CCP §1013. The clerk does not “approve” the form. It becomes part of the record automatically unless the debtor files a Motion to Tax within 10 days after service plus 5 days for mailing.
The consequence of bad service is that the costs never become part of the enforceable judgment, even though the form sits in the court file. A common misconception is that filing without serving is enough. It is not. The debtor must get notice or the form is a nullity. For example, Priya Patel, a landlord in Oakland, filed her MC-010 but forgot to mail a copy to the tenant. The sheriff refused to levy the extra $300 in costs because the proof of service was missing.
Federal Backdrop and California Specifics
Federal law does not control state-court money judgments, but the federal post-judgment interest rate under 28 U.S.C. §1961 is tied to the one-year Treasury yield, often under 5%. California is far more generous to creditors. The state constitution at Article XV, §1 sets the post-judgment rate at 10% per year on most money judgments, and 7% on judgments against public entities under CCP §685.010(b).
The plain-English meaning is that California creditors earn far more interest than federal creditors. The consequence for debtors is that ignoring a California judgment is expensive. A $20,000 unpaid judgment grows by $2,000 every year until paid. A real-world example is Marcus Johnson, who let a $15,000 judgment sit for six years and woke up to a $24,000 balance after MC-010 filings stacked the interest. The common misconception is that interest stops when the creditor files for collection. It does not. Interest runs every single day until the debtor pays.
Line-by-Line Walkthrough of MC-010
The form has a caption box at the top and seven numbered sections. Every box has a purpose, and every blank you leave creates a hole the debtor’s lawyer can use to tax your costs. Walk through each line carefully, pull receipts before you write, and never round up.
Caption Box
The caption is the section at the top with the court name, parties, and case number. Plain-English meaning: this is how the clerk knows which file the memorandum belongs in. Get the case number wrong and the form goes into a different file or gets rejected outright.
The consequence of caption errors is delay. The clerk will reject the filing, you re-file, and meanwhile your two-year window is shrinking. A real-world example is Maria Lopez, who typed her case number as “23CV01234” when the correct number was “23-CV-01234” with hyphens. Her filing bounced back twice. A common misconception is that close enough is good enough. It is not. Match the caption on the original judgment exactly, including hyphens, county code letters, and party order.
Item 1: Costs After Judgment
Item 1 is a table where you list every post-judgment cost by category. The categories listed on the form match the costs allowed under CCP §685.070(a). They include statutory fees for preparing and issuing a writ of execution, fees for filing a notice of judgment lien, fees for recording an abstract of judgment, fees for a levying officer, and approved attorney fees for enforcement.
The plain-English meaning is that not every dollar you spent qualifies. The list is closed. If a cost is not on the statute, you cannot claim it. The consequence of claiming a non-statutory cost is a successful Motion to Tax, where the judge strikes that line and may award the debtor sanctions. A real-world example is David Chen, who tried to claim $250 for hiring a private investigator to find the debtor’s bank account. The court struck it because investigator fees are not on the §685.070(a) list. A common misconception is that anything “reasonable” qualifies. The statute is exhaustive, not illustrative.
Item 2: Credit Acknowledgment
Item 2 is where you list every payment the debtor made since the judgment. You write the date received and the amount. Plain-English meaning: this is the honesty box, where the creditor admits how much money already came in.
The consequence of hiding payments is fraud and possible sanctions under CCP §128.7. The court can strike the entire memorandum and award the debtor attorney fees. A real-world example is Priya Patel, who received a $1,000 partial payment from her tenant but left it off the form. The tenant produced a canceled check, and the judge sanctioned Priya $750. A common misconception is that informal payments — like cash or partial Venmo transfers — do not count. They count. Every dollar received reduces the balance.
Item 3: Declaration of Accrued Interest
Item 3 is where you declare the interest that has piled up. You list the principal amount, the rate (usually 10%), the date interest started running, and the total accrued through a stated cutoff date. The math follows CCP §685.010.
The plain-English meaning is that interest is simple, not compound. The principal stays put, and 10% per year accrues on the unpaid balance. The consequence of mis-calculating interest is a Motion to Tax that strikes your number and replaces it with the debtor’s lower figure. A real-world example is Marcus Johnson, who used compound interest by accident and overstated his accrued interest by $400. The judge cut it. A common misconception is that interest stops when you file the memorandum. Interest keeps running until actual payment.
Items 4 Through 7: Totals and Signature
Item 4 totals the new costs. Item 5 totals the credits. Item 6 declares the new total due, including interest. Item 7 is the signature block, signed under penalty of perjury under CCP §2015.5.
The plain-English meaning is that you are swearing the numbers are true. The consequence of a false signature is perjury, which is a felony under Penal Code §118. A real-world example is a creditor in Los Angeles who inflated his sheriff fee by $500 and faced a perjury referral after the debtor pulled the actual sheriff invoice. A common misconception is that the perjury clause is a formality. It is not. Judges refer egregious cases to the District Attorney.
Worked Interest Math
The 10% rate sounds simple, but the daily calculation matters when you have partial payments. The daily rate is the principal multiplied by 0.10, divided by 365.
For a $10,000 judgment, the daily interest is $2.74. Over one year, the accrued interest is $1,000. Over 30 days, the accrued interest is $82.19. The plain-English meaning is that you should pull a calendar, count the actual days, and multiply.
The consequence of using months instead of days is small overstatements that add up across multiple memoranda. A real-world example is Maria Lopez, who used 12 even months and overstated her interest by $14 because the year had 366 days. A common misconception is that you can claim interest on costs the moment you spend them. Costs only earn interest from the date they are added by a filed MC-010 under CCP §685.090.
Partial Payments and Allocation
When the debtor pays partially, California uses the “U.S. Rule” of allocation. Payments are applied first to accrued interest, then to costs, then to principal. The rule comes from Big Bear Properties, Inc. v. Gherman (1979) and is followed by California courts.
The plain-English meaning is that until interest is paid off, the principal does not shrink. The consequence is that small payments barely dent the balance. A real-world example is David Chen, who received $200 a month from a debtor on a $5,000 judgment. The first $41.67 each month covered interest, and only $158.33 reduced principal. A common misconception is that the debtor can direct the payment to principal. The creditor controls allocation unless the parties agree otherwise in writing.
Three Real-World Scenarios
Real cases make the form click. Below are three scenarios with named creditors and the consequences of each move on MC-010.
Scenario 1: The Eviction Landlord
| Action by Priya Patel | Consequence on MC-010 |
|---|---|
| Pays $40 to record abstract of judgment | Adds $40 on Item 1 line for recording fee |
| Pays $145 sheriff fee for lockout | Adds $145 on Item 1 levying officer line |
| Receives $500 partial rent payment | Lists $500 on Item 2 credit line |
| Calculates 10% interest for 180 days on $4,000 | Adds $197.26 on Item 3 |
| Files MC-010 on day 181 | Locks in costs and interest, restarts collection clock |
Scenario 2: The Breach-of-Contract Creditor
| Action by David Chen | Consequence on MC-010 |
|---|---|
| Issues writ of execution at $40 | Adds $40 on Item 1 writ line |
| Hires registered process server for $75 | Cannot claim, not on §685.070 list |
| Records abstract for $35 in two counties | Adds $70 total on Item 1 recording line |
| Receives no payments yet | Leaves Item 2 blank with “$0” |
| Calculates one full year of 10% interest on $9,000 | Adds $900 on Item 3 |
Scenario 3: The Family-Support Creditor
| Action by Marcus Johnson’s ex-spouse | Consequence on MC-010 |
|---|---|
| Pays $30 for earnings withholding order | Adds $30 on Item 1 |
| Pays $25 sheriff fee for service of order | Adds $25 on Item 1 |
| Receives $1,200 garnished wages | Lists $1,200 on Item 2 |
| Applies payment first to interest, then costs, then principal | Reduces principal by only $400 after $800 in interest |
| Files MC-010 every six months | Keeps interest declaration current and avoids waiver |
Mistakes to Avoid
Even careful creditors slip on this form. Below are the most common errors and the price each one carries.
- Filing late. Costs older than two years are waived under CCP §685.070(b), and the court will strike them.
- Claiming non-statutory costs. Investigator fees, paralegal fees, and travel time are not on the list and trigger a Motion to Tax.
- Skipping the proof of service. Without proof, the costs never attach to the judgment, and the sheriff will not levy the extra amount.
- Using compound interest. California allows simple interest only, and compounding overstates the balance and invites sanctions.
- Forgetting partial payments. Hiding payments is fraud and can result in CCP §128.7 sanctions.
- Wrong case caption. Mismatched case numbers cause the clerk to reject the form and burn time off your two-year clock.
- Mixing pre-judgment and post-judgment costs. Pre-judgment costs go on a Memorandum of Costs (Form MC-011) at trial, not on MC-010.
- Failing to renew the judgment. Judgments expire after 10 years under CCP §683.020, and an MC-010 cannot resurrect a dead judgment.
- Using the wrong interest rate against a public entity. Public entities pay 7%, not 10%, and overcharging triggers a tax motion.
- Signing without reading. The penalty-of-perjury clause is real, and false numbers can lead to felony referrals under Penal Code §118.
How a Debtor Fights Back: Motion to Tax Costs
A judgment debtor has 10 days after service of MC-010, plus 5 days for mailing, to file a Notice of Motion to Tax Costs under CCP §685.070(c). The motion challenges specific cost items as unreasonable, non-statutory, or unsupported.
The plain-English meaning is that the debtor gets one short window to push back. The consequence of missing the window is automatic — the costs are added to the judgment with no further review. A real-world example is the case Lucky United Properties Investment, Inc. v. Lee (2010) 185 Cal.App.4th 125, where the appellate court held that a debtor’s late motion to tax could not be heard, even though some costs were arguably improper. A common misconception is that the debtor can object at any time. They cannot. The 10-day clock is jurisdictional.
What the Court Looks At
The court examines whether each cost falls inside CCP §685.070(a), whether the creditor proved actual payment, and whether the interest math is correct. The case Gorman v. Tassajara Development Corp. (2009) 178 Cal.App.4th 44 clarified that creditors must produce receipts on demand.
The plain-English meaning is that bald assertions of cost are not enough. The consequence of empty assertions is the cost gets struck. A real-world example is Priya Patel, whose $145 sheriff fee was challenged. She produced the sheriff’s receipt and won. A common misconception is that the creditor’s signature alone proves the cost. It does not when the debtor demands proof.
Do’s and Don’ts
Treat the do’s and don’ts as a quick checklist before you sign.
- Do pull every receipt before you list a cost so you can defend each line under oath.
- Do match the caption on the original judgment letter for letter so the clerk accepts the filing.
- Do serve the debtor by first-class mail with a proof of service the same day you file.
- Do file a fresh MC-010 every time you incur a new batch of enforcement costs to keep the two-year window alive.
- Do calculate interest with simple interest at 10% per year, using a daily rate of principal × 0.10 ÷ 365.
- Don’t claim attorney fees unless the original judgment expressly authorized post-judgment fees, because doing so triggers a tax motion.
- Don’t lump multiple costs into a single line because the court needs to see each item independently to rule on it.
- Don’t forget to acknowledge partial payments because hiding them is fraud and can lead to perjury referrals.
- Don’t wait until renewal to file MC-010 because the two-year window will erase older costs.
- Don’t use the federal interest rate by mistake because California’s 10% rate controls state-court judgments.
Pros and Cons of Filing MC-010
The form is powerful, but it is not a free ride. Weigh the upside against the downside.
- Pro: It adds enforcement costs to the judgment without a separate motion, saving filing fees and court time.
- Pro: It locks in interest calculations on the record, making future levies easier for the sheriff to compute.
- Pro: It puts the debtor on notice, often prompting settlement discussions.
- Pro: It documents partial payments, protecting the creditor from later claims of overcharging.
- Pro: It keeps the judgment “warm” by showing active enforcement, which courts favor at renewal time.
- Con: A defective MC-010 can trigger a Motion to Tax that strips legitimate costs along with disputed ones.
- Con: Filing repeatedly costs time and postage, and on small judgments the costs can outpace the recovery.
- Con: The form opens the creditor to scrutiny under penalty of perjury, raising the stakes if any number is off.
- Con: Service mistakes can void the entire filing and waste the two-year window.
- Con: The form alone does not collect money, and a creditor still needs writs, levies, or wage garnishments to actually get paid.
Key Entities to Know
Understanding the players helps the form make sense. The Judicial Council of California drafts the MC-010 form and updates it whenever the underlying statutes change. The California Legislature writes the Code of Civil Procedure sections that make the form binding. The county sheriff or marshal levies on the costs once they are added. The court clerk accepts and files the form. The judgment creditor and debtor are the parties whose money rides on every blank line.
The plain-English meaning is that MC-010 sits inside a larger ecosystem. The consequence of treating it as a standalone document is misuse, because the form depends on writs, abstracts, and levies to actually collect. A real-world example is Marcus Johnson’s ex-spouse, who filed three perfect MC-010 forms but never asked the sheriff to levy and collected nothing. A common misconception is that filing equals collecting. It does not.
Renewal of Judgment Interaction
A California money judgment expires 10 years after entry unless renewed under CCP §683.120. Costs and interest declared on prior MC-010 filings roll into the renewed judgment, and once renewed, they accrue another 10% per year.
The plain-English meaning is that filing MC-010 regularly grows the renewed balance and can multiply a small judgment over a decade. The consequence of skipping renewals is that the entire judgment dies, taking every cost and dollar of accrued interest with it. A real-world example is a creditor whose $5,000 judgment grew to $14,000 after ten years of MC-010 filings and a timely renewal. A common misconception is that renewal restarts the clock at the principal only. It does not. The renewed amount includes everything declared on every prior MC-010.
Court Recap of Key Rulings
Two appellate decisions shape MC-010 practice. In Lucky United Properties Investment, Inc. v. Lee (2010), the Court of Appeal held that the 10-day deadline to file a Motion to Tax is strict and that late objections fail. In Gorman v. Tassajara Development Corp. (2009), the court required creditors to substantiate cost claims with receipts when challenged.
The plain-English meaning is that MC-010 is a paper-trail game. The consequence of weak documentation is a successful tax motion. A real-world example is a Sacramento creditor who lost $2,300 in claimed costs because she could not produce sheriff receipts. A common misconception is that judges presume creditors are honest. They presume nothing once a debtor objects with evidence.
FAQs
Can I file MC-010 if my judgment is from small claims court?
Yes. Small claims judgments are enforceable like any other money judgment, and MC-010 works the same way to claim post-judgment costs and interest under CCP §116.820.
Can I claim attorney fees on MC-010?
Yes. You can claim post-judgment attorney fees only if the original judgment, contract, or statute expressly allows them, and you must file a noticed motion for those fees under CCP §685.080.
Can interest on a California judgment compound?
No. California uses simple interest at 10% per year on the unpaid principal, and compounding violates CCP §685.010.
Can I claim a private investigator’s fee?
No. Investigator fees are not listed in CCP §685.070(a), and any judge will strike them on a Motion to Tax.
Can I file MC-010 more than once?
Yes. Creditors routinely file multiple MC-010 forms over the life of a judgment to capture new costs and updated interest as collection continues.
Can the debtor object to my MC-010?
Yes. The debtor has 10 days after service plus 5 days for mailing to file a Motion to Tax Costs under CCP §685.070(c).
Can I add costs older than two years?
No. CCP §685.070(b) bars costs incurred more than two years before the filing date, and those dollars are gone forever.
Can I file MC-010 electronically?
Yes. Many California superior courts accept e-filing for post-judgment forms, and rules vary by county under California Rules of Court 2.250.
Can I use MC-010 against a government agency?
Yes. You can, but the interest rate drops to 7% under CCP §685.010(b), and you must comply with the Government Claims Act for some costs.
Can MC-010 revive an expired judgment?
No. A judgment that expires after 10 years cannot be revived by an MC-010 filing, and only a timely renewal under CCP §683.120 keeps the judgment alive.
Can I claim postage and copying costs?
No. Routine postage, copying, and clerical costs are not statutory enforcement costs under CCP §685.070(a) and will be taxed if claimed.
Can I assign MC-010 rights to a collection agency?
Yes. Judgments can be assigned under CCP §673, and the assignee then files MC-010 in its own name after recording the assignment with the court.
Related reading
- How to Fill Out California Form EJ-100 (w/Examples) + FAQs
- How to Fill Out California Form EJ-150 (w/Examples) + FAQs
- How to Fill Out California Form MC-012 (w/Examples) + FAQs
- How to Fill Out California Form MC-051 (w/Examples) + FAQs
- How to Fill Out California Form DISC-002 (w/Examples) + FAQs
- How to Fill Out California Form MC-320 (w/Examples) + FAQs
- How to Fill Out California Form CIV-010 (w/Examples) + FAQs