In Leisnoi, Inc. v. Merdes & Merdes, Professional Corp., the supreme court held that the payment of an adverse judgment does not necessarily waive the debtor’s right to appeal and potentially recover the money paid. In 1995, Merdes & Merdes (“Merdes”) secured a judgment from an arbitration panel against Leisnoi. In 2002, Leisnoi defaulted on their payment of the judgment. In 2010, the lower court issued a writ of execution and Leisnoi paid the judgment’s balance. Leisnoi subsequently appealed the lower court’s order. On appeal, Merdes argued Leisnoi waived its right to appeal by voluntarily paying the balance of the 1995 judgment. The supreme court reasoned that deeming the payment of an adverse judgment involuntary, as a matter of law, would protect the debtor’s right to an appeal, while also protecting the creditor’s interest in receiving prompt payment. Thus, the supreme court held that payment of a judgment, in the absence of a settlement, does not waive the debtor’s right to appeal.