California, United States of America
The following excerpt is from Panich v. Portney, B267586 (Cal. App. 2016):
As with unclean hands, laches is an equitable defense that it is used to bar relief. (City of Oakland v. Oakland Police & Fire Retirement System (2014) 224 Cal.App.4th 210, 248 ["Laches is based on the principle that those who neglect their rights may be barred, in equity, from obtaining relief"].) Laches, therefore, is no basis for a trial court to refuse to recognize a burden shift.3
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