n9 Varner argues extensively that Smith's abstract of judgment was voidable because Accurate Heating's recorded abstract of judgment provided Smith with constructive notice of Varner's social security number. He relies on Cal. Civil Code 1213, among other authorities, for this proposition.
We agree with Smith that the statutory and case authorities cited by Varner in support of his "constructive notice" argument concern the provision of constructive notice to subsequent purchasers and mortgagees under the state's recording statutes, which are inapplicable to abstracts of judgment.
No case authority has been cited which charges a judgment creditor with constructive rather than actual knowledge of a judgment debtor's social security and/or driver's license numbers. In addition, CCP 674 does not require a judgment creditor to check any records in order to determine a judgment debtor's social security or driver's license numbers prior to recording an abstract of judgment, a requirement that would impose enormous logistical burdens on judgment creditors.