Actions on state judgments and sealed instruments
Applied in 10 court decisions — leading case Muhlenkort v. Union County Land Trust (1995)
Most recently applied in Bryant v. Bryant (March 2026)
Source: SDC 1939, § 33.0232 (1); SL 1945, ch 144; SL 1949, ch 128, § 1.
Court decisions citing this, by year. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Except where, in special cases, a different limitation is prescribed by statute, the following civil actions other than for the recovery of real property can be commenced only within twenty years after the cause of action shall have accrued:
(1) An action upon a judgment or decree of any court of this state;
(2) An action upon a sealed instrument, except a real estate mortgage.
Official source: South Dakota Legislature. Reproduced from public-domain South Dakota statutes; confirm against the official source for the current text. Not legal advice.