For a primer on the interplay between equity and law, read this case. It is a collection action on a promissory note that matured in 1999. The trial court held it was timely filed in 2009 under the partial payment doctrine. That doctrine says the statute of limitations for suing on a note, six years, begins anew upon each partial payment. The trial court also found all the elements of the equitable defense of laches were met, and barred the claims. The court of appeals reversed, holding laches is not available as an equitable defense to a timely filed action to recover a debt. The doctrine is not an equitable extension of the limitations period. Rather, courts merely interpret and apply the statute. Separation of powers concerns do not, under the facts presented, permit an equitable doctrine to shorten the legislative determination of the time within which an action can be brought.
The Colorado Supreme Court issued its Judgement and Opinion on January 13, 2014, REVERSING the Court of Appeals.