County of Los Angeles v. Ranger Insurance

— In this case we interpret the language of Code of Civil Procedure section 668.5 to determine whether the date of entry of a judgment in Los Angeles Superior Court, which maintains a register of actions rather than a judgment book, is dependent upon whether the judgment is entered in the register of actions prior to being placed in the court file.

By way of background, we first note that prior to 1974, entry of judgment was governed exclusively by Code of Civil Procedure section 668, which required each county to maintain a judgment book and mandated that judgment was not entered until it was placed in the judgment book.

In 1974, the Legislature enacted section 668.5, providing an alternative method for the entry of judgment. Section 668.5 as originally enacted permitted counties which placed individual judgments in the file of the actions to cease use of judgment books so long as they microfilmed the judgment before placing it in the file.

In 1983, after several versions of a proposed amendment were considered by the Legislature, section 668.5 was amended to read as follows: “In -those counties where the clerk of the court places individual judgments in the file of…