OPINION
BOLGER, Judge.Steven Cleveland appeals the dismissal of his application for post-conviction relief, arguing that the statute of limitations that applied to his application was extended because he had filed a motion to correct an illegal sentence before the appeal from his conviction was concluded. We conclude that the statute of limitations was not extended by the pendency of Cleveland's motion to correct an illegal sentence. We also conclude that the superior court did not commit plain error by failing to consider issues that Cleveland did not raise in the court below, including the doctrine of equitable tolling and his due process right of access to the courts.
Background
Steven Cleveland was convicted of second-degree assault and second-degree sexual assault. Cleveland appealed, and this court affirmed his convictions and his sentence.1 His petition for hearing to the Alaska Supreme Court was denied on August 26, 2004.
While Cleveland's petition for hearing was pending before the supreme court, the United States Supreme Court issued its decision in Blakely v. Washington.2 On August 19, 2004 (before the supreme court denied his petition), Cleveland filed a motion in the superior court under Alaska Criminal Rule 85(a), in which he argued that his sentence was illegal because the sentencing judge had relied on aggravating factors that were not submitted to a jury or proven beyond a reasonable doubt. The trial court denied Cleveland's motion on January 27, 2005. This court affirmed the trial court's order,3 and Cleveland did not seek further review.
On April 10, 2007, Cleveland filed a pro se application for post-conviction relief, in which he alleged that he received ineffective assistance from his original trial counsel. Newly appointed counsel then filed an amended application for post-conviction relief in December. The amended application also alleged that trial counsel had been ineffective in handling Cleveland's direct appeal.
The State moved to dismiss the application for post-conviction relief as untimely. The State argued that the action was barred by the one-year statute of limitations contained in AS 12.72.020(a)(8B)(A), because Cleveland's conviction became final on August 26, 2004, when the Alaska Supreme Court denied his petition for hearing, but Cleveland did not file his post-conviction relief action until April 10, 2007. In response, Cleveland argued that the limitation period should have been tolled while he pursued his motion to correct an illegal sentence. The superior court granted the State's motion to dismiss, ruling that the motion did not toll the statute of limitations that applied to the application for post-conviction relief.
Cleveland now appeals.
*506Discussion
This case requires us to interpret AS 12.72.020(2a)(8), a statute of limitations that applies to an application for post-conviction relief When we interpret a statute, we "consider its language, its purpose, and its legislative history, in an attempt to give effect to the legislature's intent, with due regard for the meaning the statutory language conveys to others." 4
The statute in question provides that if a criminal defendant unsuccessfully appeals their conviction, any post-conviction action must be filed within "one year after the court's decision is final under the Alaska Rules of Appellate Procedure." 5 Under the rules of appellate procedure, an appellate decision of this court becomes final when the time expires for filing a petition for hearing, or if a petition is filed, on the day after the Alaska Supreme Court resolves the petition.6 This interpretation of the appellate rules is consistent with numerous prior decisions determining when a decision of this court becomes final.7
This construction of the statute is consistent with the purpose of the statute as expressed in its legislative history. AS 12.72.020 was included in House Bill 201, enacted in 1995.8 In the governor's transmittal letter proposing this legislation, he explained that the purpose of the bill was to "promote the finality of convictions, preserve the sanctity of jury verdicts, minimize the litigation of stale claims, and prevent the unjustified dismissal of a criminal case when reprosecution is not possible.9 The governor also stated that the bill was intended to "set limits on the ability of prisoners to challenge their convictions years after they have already pursued normal appellate procedures and lost," 10
Cleveland argues that the statute is tolled during the pendency of a motion to correct an illegal sentence. But there is nothing in the language of the statute that supports Cleveland's interpretation. The legislature specifically provided for exceptions to the statute of limitations when an applicant suffers from a mental or physical disability, when a state agent physically interferes with a timely claim, and when the application is based on newly discovered evidence.11 None of these exceptions is triggered by the filing of a motion to correct an illegal sentence.
There is likewise nothing in the appellate rules that suggests that the deadline for an application for post-conviction relief is extended by a motion to correct an illegal sentence. In other cireumstances, the rules are explicit when a post-judgment request extends or tolls the period for post-judgment review.12 In particular, a motion to correct an illegal sentence will extend the time limit for an appeal from a eriminal conviction.13 But there is nothing in the appellate rules that affects the deadline for filing an application for post-conviction relief.
Cleveland's construction would also be contrary to the intent of the statute as expressed in the legislative history. A motion to correct an illegal sentence may be filed "at any time." 14 If such a motion extended the deadline for an application for post-conviction relief, then this deadline would also be extended indefinitely. This construction would *507be contrary to the purposes of the statute to "promote the finality of convictions" and "minimize the litigation of stale claims." 15
We accordingly conclude that an appellate decision affirming a criminal convietion becomes final on the day after the Alaska Supreme Court denies a petition for hearing from this court.16 The decision affirming Cleveland's conviction became final on August 27, 2004. Cleveland did not file his application for post-conviction relief until April 10, 2007. His application was untimely because it was filed more than one year after the appellate decision was final.
On appeal, Cleveland argues that the statute of limitations is subject to equitable tolling. He did not raise this issue in the trial court, so he must show plain error before we will consider it.17 In other words, Cleveland must establish that the trial court's failure to consider equitable tolling was "so obvious that any competent judge or attorney would have recognized it.18
The cases Cleveland cites suggest that he is relying on a theory of equitable tolling that applies when "extraordinary circumstances beyond a prisoner's control make it impossible to file a petition on time.19 This theory of equitable tolling has never previously been accepted by the Alaska courts.20 And Cleveland asserts no extraordinary cireumstances that prevented him from filing during the statutory period.21 We conclude that the trial court's failure to apply equitable tolling was not plain error.
In one of the headings in his brief, Cleveland also asserts that the statute of limitations should be extended under the doe-trine of equitable estoppel. But he cites no legal authority discussing this theory.22 Cleveland has abandoned this issue by his failure to submit an adequate argument on appeal.23
Cleveland also argues that the statute of limitations on post-conviction claims violates his right to due process of law. He did not raise this issue in the superior court, so he must show plain error before we will decide this claim.
A statute of limitations that deprives a litigant of access to the courts may violate due process.24 But this right of access "is ordinarily implicated only when a legislative enactment or governmental action erects a direct and "insurmountable barrier' in front of the courthouse doors."25 For example, a civil plaintiff's right of access is not unconstitutionally burdened by a rule prohibiting their lawyer from loaning them money for living expenses, since that rule does not prohibit the plaintiff from filing suit.26
There was no plain or obvious due process violation here. Cleveland's motion to correct an illegal sentence did not affect the claims of ineffective assistance of counsel that he now seeks to raise in his post-conviction applica*508tion. Cleveland had all the information he needed to raise these post-conviction claims after his initial appeal was completed. There was thus no "insurmountable barrier" that prevented Cleveland from bringing his post-conviction application within the period provided by the statute of limitations.
Conclusion
We therefore AFFIRM the superior court's order dismissing the application for post-conviction relief.
. Cleveland v. State, 91 P.3d 965 (Alaska App.2004).
. 542 U.S. 296, 124 S.Ct. 2531, 159 L.Ed.2d 403 (2004).
. Cleveland v. State, 143 P.3d 977 (Alaska App.2006).
. Alyeska Pipeline Serv. Co. v. State, Dep't of Envil. Conservation, 145 P.3d 561, 566 (Alaska 2006) (quoting Alyeska Pipeline Serv. Co. v. DeShong, 77 P.3d 1227, 1234 (Alaska 2003)).
. AS 12.72.020(a)(3)(8).
. See Alex v. State, 210 P.3d 1225, 1227 (Alaska App.2009) (interpreting Alaska Appellate Rules 507(b) & 512(a)).
. Id. (citing cases).
. See Ch. 79, § 9, SLA 1995.
. 1995 House Journal 489.
. 1995 House Journal 490.
. See AS 12.72.020(b)(1)-(2).
. See Alaska R.App. P. 204(a)(3) (listing motions that extend the time for filing appeals in civil cases); Alaska R.App. P. 204(a)(4) (listing motions that extend the time for filing appeals in criminal cases).
. Alaska R.App. P. 204(a)(4).
. Alaska R.Crim. P. 35(a).
. 1995 House Journal 489.
. See Alex, 210 P.3d at 1227.
. Kaiser v. Umialik Ins., 108 P.3d 876, 881 (Alaska 2005).
. Simon v. State, 121 P.3d 815, 820 (Alaska App.2005).
. Brambles v. Duncan, 330 F.3d 1197, 1202 (9th Cir.2003) (quoting Miles v. Prunty, 187 F.3d 1104, 1107 (9th Cir.1999)), cert. granted, judgment vacated, Adams v. Brambles, 542 U.S. 933, 124 S.Ct. 2903, 159 L.Ed.2d 808 (2004).
. See Kaiser, 108 P.3d at 882.
. Id. (explaining that equitable tolling may be based on legal barriers preventing access to the court or extraordinary events like wars); Spitsyn v. Moore, 345 F.3d 796, 800-01 (9th Cir.2003) (allowing equitable tolling for egregious performance of appointed counsel).
. See generally Kaiser, 108 P.3d at 880 (discussing the proof required for this type of claim).
. See Barios v. Brooks Range Supply, Inc., 26 P.3d 1082, 1088 (Alaska 2001) (explaining that an issue given only cursory treatment in the argument section of a brief will not be considered on appeal).
. See Sands ex rel. Sands v. Green, 156 P.3d 1130, 1135 (Alaska 2007).
. Id. at 1134 (citing Varilek v. City of Houston, 104 P.3d 849, 853-55 (Alaska 2004)).
. In re KAH., 967 P.2d 91, 95-96 (Alaska 1998).