In Longview International, Inc. v. Stirling the Court of Appeal for the Sixth District concludes that the recording of an abstract of judgment is a procedural act that is retroactively validated once a suspended corporation’s powers are reinstated.
An abstract of judgment recorded when a corporation is suspended for failure to pay franchise taxes is not void. At the time of recording, even though a corporation is suspended, the abstract of judgment is capable of being enforced upon the corporation obtaining a revival of its corporate powers. Revival retroactively validates the lien and makes the abstract enforceable.
The fact that revival occurred after the transfer of property is of no merit. A recorded abstract that complies with all statutory requirements is not void and provides notice to the transferee that the judgment lien may be enforced upon revival of the corporation’s powers.