Appellate Insights

California judgments are enforceable upon entry.  True, posting a bond can stay enforcement of money judgments during an appeal.  But what about during the post-judgment motion phase, before an appeal is filed?  And what about clients who need time to get a bond in place?  Here are two options:

• Consider inquiring whether the other side will stipulate not to enforce the judgment during this relatively short period.

• Alternatively, California trial courts have discretion to stay judgment enforcement for up to 10 days after the last day to file a notice of appeal.  A judgment debtor can ask the judge to issue such a stay, before or after entry of judgment—and such requests are often granted.

►  The practical message.  Getting hit with a large verdict can be destabilizing.  To buy time for your client to explore bonding options and to let the post-judgment motion process play out, add a temporary stay of enforcement request to your short list of post-verdict tasks.