Court of Appeals Holds that Defense of Laches Does Not Apply to Actions at Law for Money Damages
On July 25, 2013, the District of Columbia Court of Appeals decided Naccache v. Taylor, No. 11-CV-392, slip op. (D.C. July 25, 2013), in which it considered, inter alia, whether the trial court properly rejected the defendant’s laches defense in a medical malpractice action that resulted in a judgment awarding money damages to the plaintiff. Id. at 5-16. By way of background, the laches defense, as traditionally construed by courts of equity, provided that “[a] defendant could prevail if she could show on a particular set of facts that the plaintiff’s delay [in seeking judicial relief] was unreasonable and that the delay worked to the defendant’s detriment.” Id. at 7. In this case, the Court of Appeals considered, inter alia, “whether laches may cut off actions at law [i.e., for money damages] that are authorized under a statute of limitations,” an issue that it had not “considered . . . squarely” in any prior published decision. Id. at 9. The Court of Appeals held that “the defense of laches does not apply to purely legal claims,” i.e., actions at law for money damages. Id. at 6. In reaching that conclusion, it stated that, “[l]ike the majority of state courts that have considered the issue, the District of Columbia federal courts . . . do not permit laches to be raised as a defense to claims at law,” id. at 10-11, and the Court of Appeals “ha[s] never upheld the defense of laches to cut off actions at law for money damages.” Id. at 12. It further stated that, “[e]ven if we were to come to this issue on a clean slate, we see little to gain and much to lose by applying the equitable defense of laches to cut off claims at law.” Id. at 13. In particular, it stated, “[t]o import laches as a defense to actions at law would pit the legislative value judgment embodied in a statute of limitations . . . against the equitable determinations of individual judges,” id. at 14, and would undermine the “predictable guideposts” provided by statutes of limitations which “are not discretionary or applied case-by-case.” Id. at 15. As the Court of Appeals found no reversible error with respect to this issue or any other issue decided by the trial court, it affirmed the judgment for the plaintiff.