Rule 2.621.Proceedings Supplementary to Judgment

Current through May 1, 2026 · Last verified July 6, 2026

In one sentenceRule 2.621 lets a Michigan judgment creditor pursue supplementary proceedings -- creditor's-bill-style relief, statutory aid in execution, and other collection tools -- against a debtor's assets, covering the pleading requirements, subpoenas and orders freezing asset transfers, receiver appointments, and the leave-of-court and bonding requirements for a repeat or appealed proceeding.

Full Text of Rule 2.621

Text sizeJump to: (A) (B) (C) (D) (E) (F) (G) (H)

(A) Relief Under These Rules. When a party to a civil action obtains a money judgment, that party may, by motion in that action or by a separate civil action:

(1) obtain the relief formerly obtainable by a creditor's bill;

(2) obtain relief supplementary to judgment under MCL 600.6101-600.6143 and

(3) obtain other relief in aid of execution authorized by statute or court rule.

(B) Pleading.

(1) If the motion or complaint seeks to reach an equitable interest of a debtor, it must be verified, and

(a) state the amount due the creditor on the judgment, over and above all just claims of the debtor by way of setoff or otherwise, and

(b) show that the debtor has equitable interests exceeding $100 in value.

(2) The judgment creditor may obtain relief under MCL 600.6110, and discovery under subchapter 2.300 of these rules.

(C) Subpoenas and Orders. A subpoena or order to enjoin the transfer of assets pursuant to MCL 600.6119 must be served under MCR 2.105. The subpoena must specify the amount claimed by the judgment creditor. The court shall endorse its approval of the issuance of the subpoena on the original subpoena, which must be filed in the action. The subrule does not apply to subpoenas for ordinary witnesses.

(D) Order Directing Delivery of Property or Money.

(1) When a court orders the payment of money or delivery of personal property to an officer who has possession of the writ of execution, the order may be entered on notice the court deems just, or without notice.

(2) If a receiver has been appointed, or a receivership has been extended to the supplementary proceeding, the order may direct the payment of money or delivery of property to the receiver.

(E) Receivers. When necessary to protect the rights of a judgment creditor, the court may, under MCR 2.622, appoint a receiver in a proceeding under subrule (A)(2), pending the determination of the proceeding.

(F) Violation of Injunction. The court may punish for contempt a person who violates the restraining provision of an order or subpoena or, if the person is not the judgment debtor, may enter judgment against the person in the amount of the unpaid portion of the judgment and costs allowed by law or these rules or in the amount of the value of the property transferred, whichever is less.

(G) New Proceeding. If there has been a prior supplementary proceeding with respect to the same judgment against the party, whether the judgment debtor or another person, further proceedings may be commenced against that party only by leave of court. Leave may be granted on ex parte motion of the judgment creditor, but only on a finding by the court, based on affidavit of the judgment creditor or another person having personal knowledge of the facts, other than the attorney of the judgment creditor. The affidavit must state that

(1) there is reason to believe that the party against whom the proceeding is sought to be commenced has property or income the creditor is entitled to reach, or, if a third party, is indebted to the judgment debtor;

(2) the existence of the property, income, or indebtedness was not known to the judgment creditor during the pendency of a prior supplementary proceeding; and

(3) the additional supplementary proceeding is sought in good faith to discover assets and not to harass the judgment debtor or third party.

(H) Appeal; Procedure; Bonds. A final order entered in a supplementary proceeding may be appealed in the usual manner. The appeal is governed by the provisions of chapter 7 of these rules except as modified by this subrule.

(1) The appellant must give a bond to the effect that he or she will pay all costs and damages that may be awarded against him or her on the appeal. If the appeal is by the judgment creditor, the amount of the bond may not exceed $200, and subrules (H)(2)-(4) do not apply. If the appeal is by a party other than the judgment creditor, subrules (H)(2)- (4) apply.

(2) If the order appealed from is for the payment of money or the delivery of property, the bond of the appellant must be in an amount at least double the amount of the money or property ordered to be paid or delivered. The bond must be on the condition that if the order appealed from is affirmed in whole or in part the appellant will

(a) pay the amount directed to be paid or deliver the property in as good condition as it is at the time of the appeal, and

(b) pay all damages and costs that may be awarded against the appellant.

(3) If the order appealed from directs the assignment or delivery of documents by the appellant, the documents must be delivered to the clerk of the court in which the proceeding is pending or placed in the hands of an officer or receiver, as the judge who entered the order directs, to await the appeal, subject to the order of the appellate courts.

(4) If the order appealed from directs the sale of real estate of the appellant or delivery of possession by the appellant, the appeal bond must also provide that during the possession of the property by the appellant, or any person holding under the appellant, he or she will not commit or suffer any waste of the property, and that if the order is affirmed he or she will pay the value of the use of the property from the time of appeal until the delivery of possession.

End

Amendment History

Michigan tracks the orders that adopt and amend its Court Rules in a separate administrative record rather than printing a history note beneath each rule in the compiled rules text reproduced here. The text above is verified current through the source’s own May 1, 2026 update; for the full order-by-order history of this rule, see the Michigan Supreme Court’s rules and orders page.

Plain-English Summary

Winning a money judgment is only the first step; Rule 2.621 gives the judgment creditor tools to collect it. By motion in the same action or through a separate civil action, a judgment creditor can pursue the relief a creditor's bill used to provide, seek the statutory supplementary relief in MCL 600.6101 through 600.6143, or ask for any other relief in aid of execution a statute or court rule allows. Going after a debtor's equitable interests takes a verified pleading stating the amount owed and showing the debtor holds equitable interests worth more than $100, and the creditor can also use the discovery tools in Rule 2.302's subchapter to track down assets.

A subpoena or an order enjoining the transfer of assets has to be served under Rule 2.105, specify the amount the judgment creditor claims, and get the court's endorsed approval before it's filed — though this doesn't reach an ordinary witness subpoena. The court can order money or property delivered to the officer holding the writ of execution, or to a receiver if one has been appointed, and can appoint a receiver under Rule 2.622 when necessary to protect the creditor's rights while the proceeding plays out. Violating the restraining piece of an order or subpoena can draw contempt, or, for a non-debtor violator, a judgment for the lesser of the unpaid judgment or the value of the property transferred away. And because these proceedings can be used to harass a debtor, a second supplementary proceeding against the same party needs the court's leave, granted only on an affidavit showing newly discovered assets or income and a good-faith reason for going back to the well. An appeal from a final order in these proceedings follows Chapter 7's ordinary rules but layers on its own bonding requirements, scaled to whether the appellant is the judgment creditor or someone else and to what the underlying order directed.

Frequently Asked Questions

What can a Michigan judgment creditor do to collect a money judgment?

Move in the same action, or file a separate action, for creditor's-bill-style relief, statutory supplementary relief under MCL 600.6101-600.6143, or any other relief in aid of execution a statute or court rule authorizes.

What does it take to reach a debtor's equitable interests?

A verified pleading stating the amount due on the judgment and showing the debtor has equitable interests worth more than $100.

Can I bring a second supplementary proceeding against the same debtor?

Only with the court's leave, granted on an affidavit showing that newly discovered property, income, or indebtedness wasn't known during the earlier proceeding and that the new proceeding is sought in good faith, not to harass.

Is there a bond requirement to appeal a supplementary-proceeding order?

Yes. The appellant must post a bond, with the amount and conditions varying depending on whether the judgment creditor or another party is appealing and what the underlying order required.

Source & verification. The rule text is reproduced verbatim from the official Michigan Court Rules (MCR 2.621). Prescribed by the Supreme Court of Michigan (Mich. Const. 1963, art. VI, § 5). The plain-English summary is original and written by us. Last verified July 6, 2026. · Official source

Also known as: proceedings supplementary to judgment Michigancreditor's bill Michigancollecting a judgment Michigan