Raso v. Wall

In Raso v. Wall, 884 A.2d 391, 394 (R.I. 2005), the Supreme Court construed R.I. Gen. Laws 10-9-1-3 as allowing the State to defend an application for post-conviction relief on grounds of laches. 884 A.2d at 395. In that case, the State asserted the defense of laches when the applicant filed for post-conviction relief some twenty-eight years after entry of his guilty plea. Id. at 393-94. While the statute provides that "an application for post-conviction relief may be filed at any time," the court reasoned that adhering to the "plain meaning" approach to statutory construction would lead to an absurd result. Id. at 395; R.I. Gen. Laws 10-9.1-3. Because of potential prejudice to the State, the statutory term "any time" was construed to mean "any reasonable time." Raso, 884 A.2d at 395. The case was remanded to the Superior Court to enable it to make the necessary factual findings with respect to the laches issue.