Texas Bail Bond Bill-of-Review Deadline Calculator
After a forfeiture judgment becomes final, a Texas surety has exactly two years to ask the court to give some of the money back. Enter the date the judgment became final and this tool returns the article 22.17 deadline to file a special bill of review, the last remedy on the board once payment is due.
Legally reviewed by Reggie London, TX Bar #24043514.
Bill-of-review deadline calculator
Enter the date your final judgment of forfeiture became final. The tool adds two years and returns the outer limit to file a special bill of review under article 22.17. Because a bill of review is discretionary and the surety carries the burden, treat the result as the last day to act, not a target.
Informational only — not legal advice and not a prediction of any outcome. The two-year window runs from the date the judgment became final, which may differ from the date it was signed; confirm the exact date with counsel.
Once a judgment on a bond forfeiture is final, most of a bondsman’s options have closed — but not all of them. Under article 22.17 of the Code of Criminal Procedure, a surety has two years after the final judgment to file a special bill of review and ask the court, in equity, to remit part of what is owed.1 This calculator plots that two-year date for you. It is the companion tool to our in-depth guide on the special bill of review, part of the post-judgment bond forfeiture series.
How this calculator works
The tool adds two years to the date you enter, because Code of Criminal Procedure article 22.17 lets a surety file a special bill of review only within two years after the forfeiture judgment becomes final. It keeps the month and day and advances the year by two, then flags when that window has already closed.
The calculation mirrors the statute: article 22.17 fixes a single outer limit of two years after the final judgment, and the tool returns that date.1 It keeps the month and day you entered and moves the year forward by two, so a judgment that became final on June 21, 2026 yields a deadline of June 21, 2028.
What date to enter
Enter the date the judgment became final, which is not always the date it was signed — a timely motion for new trial or appeal can move finality later. Because the difference can cost a surety the whole remedy, the tool labels the input as the date the judgment became final and asks you to confirm it with counsel rather than guessing.
The leap-year edge
If the judgment became final on February 29, there is no February 29 two years later, so the date normalizes forward to March 1. The tool notes this and tells you to file well before the end of the window; it never relies on a borderline day.
What is the two-year rule under article 22.17?
Article 22.17 of the Code of Criminal Procedure lets a surety, within two years after a final forfeiture judgment, file a special bill of review and ask the court to remit part of what is owed. It is a separate equitable remedy from remittitur before final judgment under article 22.16, and the two-year clock is the hard outer limit.
The remedy this calculator times is the special bill of review in article 22.17 of the Code of Criminal Procedure. Within two years after a final judgment of forfeiture, a surety may file a special bill of review and ask the trial court, sitting in equity, to remit a portion of the amount.1 The two-year period is the deadline the tool returns — miss it and the bill of review is no longer available.
How it differs from remittitur before final judgment
Do not confuse the bill of review with remittitur under article 22.16, which operates before the judgment becomes final and is discretionary with the court.2 The Court of Criminal Appeals held in Lyles v. State that the once-mandatory language of article 22.16(a) is void, so even pre-final remittitur is reviewed only for an abuse of discretion.4 The bill of review is the after-final-judgment cousin of that relief, and the two-year window in article 22.17 is the one this tool tracks. The final judgment itself is entered under article 22.14.3
What can a bill of review actually save?
Not the whole judgment. Article 22.17(a) lets the court remit the forfeited amount less court costs, the county's reasonable costs of returning the principal to custody, and interest accrued on the bond from the date of forfeiture. The bill of review trims those items from the judgment; it does not wipe it out.
A special bill of review is not an eraser. Under article 22.17(a), if the court grants relief it may remit the amount of the forfeiture less three things: the costs of court, the reasonable costs the county incurred to return the principal to custody, and the interest accrued on the bond obligation from the date of the forfeiture.1 In other words, even a successful bill of review leaves those deductions in place.
Estimating the net exposure
Because the math turns on those deductions, the realistic question is not “will the judgment vanish” but “how much could be left.” Our remittitur estimator lets you subtract the article 22.17(a) items from the bond amount to picture a net range. Keep in mind the bond’s penal sum is the ceiling: a forfeiture judgment cannot exceed it and bears no post-judgment interest, so nothing compounds while you decide.5
Who bears the burden on a bill of review?
The surety does. In McKenna v. State the Court of Criminal Appeals confirmed that on a special bill of review the surety bears the burden, and it identified six non-exclusive equitable factors a court weighs. Because the remedy is discretionary, filing early and building the equities matters as much as hitting the deadline.
The reason the deadline alone is not enough is that the relief is discretionary and the surety carries the load. In McKenna v. State, the Court of Criminal Appeals held that on a special bill of review the surety bears the burden of showing it is entitled to relief, and it set out six non-exclusive equitable factors the court may weigh in deciding whether to remit.6 A bill of review filed inside the two-year window can still be denied if the equities do not line up.
Why timing and preparation both matter
That is why this calculator frames the result as the last day to act rather than a goal. The strongest bills of review are filed well before the two-year mark with the equitable showing already assembled. For the full treatment of the six factors and how courts apply them, read our guide on the special bill of review.
Other post-judgment calculators
Plot the rest of your deadlines with these companion tools. Each shows the statute behind every interval and is informational only, not legal advice and not a prediction of any outcome.
Where do you defend bail bond businesses?
We represent sureties, bail bond companies, and bondsmen throughout North Texas, with a base in Frisco and regular practice in the courts and bail bond boards of Collin, Dallas, Denton, and Tarrant counties, and surrounding jurisdictions.
A forfeiture judgment is entered and enforced in the court where the criminal case sits, and the related license consequences run through the bail bond board of the county that issued the license. Our firm appears across the DFW metroplex — Collin, Dallas, Denton, Tarrant, Rockwall, Kaufman, Ellis, Johnson, and Hunt counties — and coordinates with corporate sureties and their producing agents wherever the paper was written. From our office at 5899 Preston Rd, Suite 101, Frisco, TX 75034, we handle post-judgment payment and supersedeas decisions, remittitur and bill-of-review practice, forfeiture appeals, and the licensing fallout as one integrated practice.
Bill-of-review deadline calculator FAQ
Common questions about the two-year deadline to file a Texas special bill of review on a bail bond forfeiture judgment. General information, not legal advice for your case.
How is the bill-of-review deadline calculated?
The tool adds two years to the date you enter, because Code of Criminal Procedure article 22.17 lets a surety file a special bill of review only within two years after the forfeiture judgment becomes final. It keeps the same month and day and advances the year by two.
When does the two-year clock start?
On the date the final judgment of forfeiture becomes final. That is not always the signing date — a timely motion for new trial or appeal can push finality later, so confirm the operative date with counsel before relying on the result.
What is a special bill of review?
It is the equitable remedy in article 22.17 that lets a surety ask the trial court, after a forfeiture judgment is final, to remit part of the amount owed. It is separate from remittitur before final judgment under article 22.16.
Is the court required to grant a bill of review?
No. The special bill of review is discretionary. The court decides whether equity supports remitting any of the judgment, and a timely filing can still be denied if the equities do not favor the surety.
Who has the burden of proof?
The surety. In McKenna v. State the Court of Criminal Appeals confirmed the surety bears the burden on a special bill of review and identified six non-exclusive equitable factors the court may weigh.
What can a bill of review actually save?
Under article 22.17(a) the court may remit the forfeited amount less court costs, the county’s reasonable costs of returning the principal to custody, and interest accrued on the bond from the date of forfeiture. It trims the judgment; it does not erase it.
What happens if the two-year window closes?
The special bill of review is no longer available once the two-year window under article 22.17 closes. The tool flags a deadline that has already passed and advises speaking with counsel about whether any other relief remains.
Is this calculator legal advice?
No. It applies a single statutory interval to the date you enter and is not legal advice and not a prediction of any outcome. Deadlines and the date of finality turn on case-specific facts, so confirm yours with counsel.
Talk to a lawyer before your two-year window closes
If a final judgment of forfeiture has been entered against your company, the two-year clock to file a special bill of review is already running. Tell us your judgment date and what happened, and we will help you weigh a bill of review, the equitable factors a court will weigh, and any other post-judgment relief. Consultations are confidential and there is no charge to evaluate your matter.
Prefer to call?
(972) 370-5060Speak directly with a Co-Founding Partner. Available 24/7 for time-sensitive forfeiture, supersedeas, and appeal deadlines.
info@landllawgroup.com
5899 Preston Rd, Suite 101
Frisco, TX 75034
Statutes & cases cited
Statutory citations link to the official Texas Constitution and Statutes site. Case citations are provided in Bluebook form.
Statutes
- Tex. Code Crim. Proc. art. 22.17 (“Special Bill of Review” — within two years after a final judgment of forfeiture, a surety may file a special bill of review; the court may remit the forfeited amount less, per art. 22.17(a), costs of court, the county’s reasonable costs of returning the principal to custody, and interest accrued on the bond from the date of forfeiture). statutes.capitol.texas.gov/Docs/CR/htm/CR.22.htm.
- Tex. Code Crim. Proc. art. 22.16 (“Remittitur After Forfeiture” — discretionary remittitur before the forfeiture judgment becomes final). statutes.capitol.texas.gov/Docs/CR/htm/CR.22.htm.
- Tex. Code Crim. Proc. art. 22.14 (“Judgment Final” — entry of the final judgment of forfeiture against the principal and sureties). statutes.capitol.texas.gov/Docs/CR/htm/CR.22.htm.
Cases
- Lyles v. State, 850 S.W.2d 497 (Tex. Crim. App. 1993) (the mandatory language of art. 22.16(a) is void; remittitur after forfeiture is discretionary and is reviewed only for an abuse of discretion).
- Bailout Bonding Co. v. State, 797 S.W.2d 275 (Tex. App.—Dallas 1990, pet. ref’d) (a bond-forfeiture judgment is penal, must not exceed the penal sum fixed by the bond, and bears no post-judgment interest).
- McKenna v. State, 247 S.W.3d 716 (Tex. Crim. App. 2008) (on a special bill of review under art. 22.17 the surety bears the burden; the court identified six non-exclusive equitable factors a trial court may weigh in deciding whether to remit).
About your attorneys
L and L Law Group, PLLC is a Frisco, Texas criminal-defense firm led by two Co-Founding Partners. Post-judgment forfeiture work sits at the intersection of criminal procedure, civil enforcement, and business litigation — the core of what we do for sureties and bondsmen.
Reggie London represents sureties and bondsmen in post-judgment forfeiture matters — payment and supersedeas decisions, remittitur and bill-of-review practice, and forfeiture appeals — across North Texas. He maintains both state and federal practices and is the author and reviewer of record for this guide.
Njeri London handles criminal-defense and bond-related matters for the firm’s clients, including the contract and indemnity questions that surface when a forfeiture judgment reaches indemnitors and collateral-pledgors. She practices throughout the Collin, Dallas, Denton, and Tarrant county courts.
Attorney advertising. This page is for general information about Texas post-judgment bail-bond forfeiture law and is not legal advice. No attorney–client relationship is formed by reading it or by sending us a message. Outcomes depend on the specific facts and applicable law of each matter; nothing here is a prediction or assurance of any result. Do not send confidential information before a written engagement is in place. L and L Law Group, PLLC · 5899 Preston Rd, Suite 101, Frisco, TX 75034 · (972) 370-5060 · info@landllawgroup.com.