unclean hands doctrine in Pennsylvania

41 Pennsylvania opinions name it 6 courts 1954–2026 12 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (18)

Case	Followed	Cited
Shapiro v. Shapirogreen pa · 1964 · cited in 11 Pennsylvania opinions naming this issue, 1965–2022 2 sentences 2019“Application of the unclean hands doctrine is confined to willful misconduct which concerns the particular matter in litigation.” Shapiro v. Shapiro, 204 A.2d 266, 268 (Pa. 1964). - 12 - J-A28019-18 Mother claims that the doctrine of unclean hands prohibits Father from receiving a downward modification of his child support obligations. 2018See Shapiro v. Shapiro, 204 A.2d 266, 268 (Pa. 1964) (“Application of the unclean hands doctrine is confined to willful misconduct which concerns the particular matter in litigation.”).	8	11
In Re Estate of Pedrickgreen pa · 1984 · cited in 7 Pennsylvania opinions naming this issue, 1997–2018 2 sentences 2018II) Unclean Hands Petitioner raises two arguments in asserting that Respondent should be denied her spousal share due to the doctrine of unclean hands: (1) Respondent's hands are unclean due to her allegedly committing marriage fraud and (2) Respondent's hands are unclean due to her making 6We further note that the record does not establish the existence of any agreement between Decedent and Respondent to enter into their marriage solely for the purpose of aiding Respondent in evading immigration laws. 13 "willful and 'material representations regarding the bona fides of her alleged marriage t 2018II) Unclean Hands Petitioner raises two arguments in asserting that Respondent should be denied her spousal share due to the doctrine of unclean hands: (1) Respondent's hands are unclean due to her allegedly committing marriage fraud and (2) Respondent's hands are unclean due to her making 6We further note that the record does not establish the existence of any agreement between Decedent and Respondent to enter into their marriage solely for the purpose of aiding Respondent in evading immigration laws. 13 "willful and 'material representations regarding the bona fides of her alleged marriage t	6	7
Terraciano v. Commonwealth, Department of Transportationgreen pa · 2000 · cited in 4 Pennsylvania opinions naming this issue, 2010–2026 2 sentences 2026The trial court summarily dismissed this claim, because, as the Tenants admit, under the doctrine of unclean hands, a “court may deprive a party of equitable relief.” Id. at 8 (quoting Terraciano v. Commonwealth, Department of Transportation, 753 A.2d 233, 237 (Pa. 2000) (emphasis added). 2024Under the doctrine of unclean hands, a court may deprive a party of equitable relief when that party “is guilty of bad conduct relating to the matter at issue.” Belleville, 118 A.3d at 1199 (quoting Terraciano v. Dep’t of Transp., Bureau of Driver Licensing, 753 A.2d 233, 237-38 (Pa. 2000)).	3	4
Barcia v. Fenlongreen pacommwct · 2012 · cited in 3 Pennsylvania opinions naming this issue, 2017–2026 2 sentences 2026Sheils as Trust for Smith & Morris Holdings, LLC v. Bartles, 295 A.3d 302 , 308 (Pa. Cmwlth. 2023). 7 In a proceeding seeking injunctive relief, under the doctrine of unclean hands, “[a] court may deprive a party of equitable relief where, to the detriment of the other party, the party applying for such relief is guilty of bad conduct relating to the matter at issue.” Barcia v. Fenlon, 37 A.3d 1, 5 (Pa. Cmwlth. 2012). 10 “Collateral estoppel, or issue preclusion, is a doctrine which prevents the re-litigation of an issue in a later action, despite the fact that it is based on a cause of action 2022In their sixth preliminary objection (PO 6), Respondents argue that the Petition should be dismissed based on the doctrine of unclean hands, under which a court may deny equitable relief when the person seeking relief has acted improperly, in violation of applicable duties, with respect to the matter at issue, citing Barcia v. Fenlon, 37 A.3d 1, 6-7 (Pa. Cmwlth. 2012).	3	3
Stauffer v. Stauffergreen pa · 1976 · cited in 3 Pennsylvania opinions naming this issue, 2014–2025 2 sentences 2025Additionally, a defendant can raise the equitable doctrine of unclean hands where “the wrongdoing of the plaintiff directly affects the equitable relationship subsisting between the parties and is directly connected with the matter in controversy.” Stauffer v. Stauffer, 351 A.2d 236, 244 (Pa. 1976). 2015Our Supreme Court described the unclean hands doctrine as follows: “The bar of unclean hands is applicable in Pennsylvania only where the wrongdoing of the plaintiff directly affects the equitable relationship subsisting between the parties and is directly connected with the matter in controversy.” Stauffer v. Stauffer, 351 A.2d 236, 244-45 (Pa. 1976).	2	3
Morgan, D. v. Morgan, S.green pasuperct · 2018 · cited in 2 Pennsylvania opinions naming this issue, 2022–2025 2 sentences 2025See Morgan v. Morgan, 193 A.3d 999, 1005 (Pa. Super. 2018) (“The doctrine of unclean hands requires that one seeking equity act fairly and without fraud or deceit as to the controversy at issue.”) (citation, quotation marks, and emphasis omitted). 2022Senator Muth further claims that her conduct was not fraudulent, deceitful, or unfair, which is required for the doctrine of unclean hands, citing Morgan v. Morgan, 193 A.3d 999, 1005 (Pa. Super. 2018).	2	2
Jacobs v. Hallorangreen pa · 1998 · cited in 2 Pennsylvania opinions naming this issue, 2014–2016 2 sentences 2016Lastly, with respect to Landowner’s “unclean hands” argument, we are guided by the following: The Pennsylvania Supreme Court has explained the doctrine of unclean hands as “a self-imposed ordinance that closes the doors of a court of equity to one tainted with inequitableness or bad faith relative to the matter in which he seeks relief, however improper may have been the behavior of the defendant.” Jacobs v. Halloran, 710 A.2d 1098, 1103 (Pa. 1999), citing Shapiro v. Shapiro, 204 A.2d 266, 268 (1964). 2014See, e.g., Jacobs v. Halloran, 551 Pa. 350 , 710 A.2d 1098, 1103-04 (1998) (defendant in motor vehicle accident case was not entitled to equitable remedy of judgment of non pros for plaintiff’s delay in prosecuting action, where defendant waited more than two years after filing of complaint before admitting that she was passenger in vehicle instead of driver; defendant "came before the court with unclean hands .... [her] dishonesty regarding the identity of the driver of the vehicle constitutes bad faith which is directly relevant to the delay in prosecution from which she seeks relief.	2	2
In Re RDgreen pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024 1 sentence 2024Id. at 24-26. -6- J-A26005-23 be waived.” In re R.D., 44 A.3d 657, 674 (Pa. Super. 2012) (citation omitted).	1	1
Mazzitti & Sullivan Counseling Services, Inc. v. Department of Public Welfaregreen pacommwct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024 1 sentence 2024Welfare, 7 A.3d 875, 882 (Pa. Cmwlth. 2010) (citation omitted)).) Unclean hands applies here, according to the Secretary, because declaratory and injunctive relief— the relief sought in this case—are equitable in nature.	1	1
Hurtt v. Stironegreen pa · 1965 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023 1 sentence 2023See Hurtt v. Stirone, 206 A.2d 624, 626-27 (Pa. 1965) (finding one attempting to benefit from the commission of a felony ― extortion ― should be barred from recovery, but distinguishing convictions of minor matters such as traffic tickets and “major criminal convictions”); Pennsylvania Turnpike Commission v. United States Fidelity and Guaranty Company, 194 A.2d 423, 427 (Pa. 1963) (determining that Turnpike Commissioner’s conviction for conspiracy to defraud the Commission and for misbehavior in office relating 9 The United States Supreme Court has also adopted the broad principle of the uncle	1	1
Pennsylvania Turnpike Commission v. United States Fidelity & Guaranty Co.green pa · 1963 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023 1 sentence 2023See Hurtt v. Stirone, 206 A.2d 624, 626-27 (Pa. 1965) (finding one attempting to benefit from the commission of a felony ― extortion ― should be barred from recovery, but distinguishing convictions of minor matters such as traffic tickets and “major criminal convictions”); Pennsylvania Turnpike Commission v. United States Fidelity and Guaranty Company, 194 A.2d 423, 427 (Pa. 1963) (determining that Turnpike Commissioner’s conviction for conspiracy to defraud the Commission and for misbehavior in office relating 9 The United States Supreme Court has also adopted the broad principle of the uncle	1	1
In the Interest of T.P.green pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023 1 sentence 2023Accordingly, we cannot say that the Orphans’ Court erred in declining to apply the doctrine of laches in this matter.6 ____________________________________________ 6 Although the Orphans’ Court declined to apply laches based on the doctrine of unclean hands, “it is a well-settled doctrine in this Commonwealth that a trial court can be affirmed on any valid basis appearing of record.” In re T.P., 78 A.3d 1166, 1170 (Pa. Super. 2013). - 10 - J-A24038-21 Mark also asserts that the Orphans’ Court should have also imposed a surcharge on Christine because she, too, breached her fiduciary duties as c	1	1
Simeone v. Simeonegreen pa · 1990 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017 2 sentences 2017Husband contends that Wife is barred from obtaining relief by the equitable doctrine of unclean hands 6 and by the Pennsylvania Supreme Court’s holding in Simeone v. Simeone, 525 Pa. 392 , 581 A.2d 162, 165 (1990). 2017Husband contends that Wife is barred from obtaining relief by the equitable doctrine of unclean hands 6 and by the Pennsylvania Supreme Court’s holding in Simeone v. Simeone, 525 Pa. 392 , 581 A.2d 162, 165 (1990).	1	1
Commonwealth v. Dunsongreen pa · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015 1 sentence 2015See In re W.H., 25 A.3d 330 , 339 n.3 (Pa.Super. 2011) (quoting In re A.C., 991 A.2d 884, 897 (Pa.Super. 2010)) (“[W]here an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.”).	1	1
In Re WHgreen pasuperct · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015 1 sentence 2015See In re W.H., 25 A.3d 330 , 339 n.3 (Pa.Super. 2011) (quoting In re A.C., 991 A.2d 884, 897 (Pa.Super. 2010)) (“[W]here an appellate brief fails to provide any discussion of a claim with citation to relevant authority or fails to develop the issue in any other meaningful fashion capable of review, that claim is waived.”).	1	1
Salomon Smith Barney Inc. v. Vockelgreen paed · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000 1 sentence 2000Unfortunately for RHI, however, the doctrine of unclean hands does not apply to a defendant in an equity action. “[I]n determining the issue of clean hands, we look solely at the conduct of the plaintiff — the one who seeks the aid of the chancellor — and not the conduct of the defendant.” Salomon Smith Barney Inc. v. Vockel, 2000 WL 558580, *4 (E.D.	1	1
Sorokin v. Krasnergreen pasuperct · 1981 · cited in 1 Pennsylvania opinions naming this issue, 1984–1984	1	1
Universal Builders, Inc. v. Moon Motor Lodge, Inc.green pasuperct · 1968 · cited in 1 Pennsylvania opinions naming this issue, 1977–1977	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (18)

Case	Cited	Years
Goebel Brewing Co. v. Esslingers, Inc. green pa · 1953 2 sentences 1996Goebel Brewing Company v. Esslingers, Inc., 373 Pa. 334 , 95 A.2d 523 (1953). 1996Goebel Brewing Company v. Esslingers, Inc., 373 Pa. 334 , 95 A.2d 523 (1953).	2	1963–1996
Goldberg v. Goldberg green pa · 1953 2 sentences 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d	2	1954–1963
Walacavage v. Walacavage green pasuperct · 1951 2 sentences 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d	2	1954–1963
Dales v. Muir green pa · 1944 2 sentences 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d	2	1954–1963
Robinson v. Goldberg neutral pa · 1938 2 sentences 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d	2	1954–1963
Delaware, Lackawanna & Western R. R. v. Stroudsburg, Water Gap neutral · 1927 2 sentences 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d 1954Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232, 238 . . . .” Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .	2	1954–1963
Valley Smokeless Coal Co. v. Manufacturers' Water Co. neutral pa · 1930 2 sentences 1963Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232 , 238 . . . .’ Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .” Holst v. Butler, 379 Pa. 124 , 108 A. 2d 1954Co. v. Stroudsburg, Water Gap & Portland Street Railway Co., 289 Pa. 131, 138 ; Valley Smokeless Coal Co. v. Manufacturers’ Water Co., 302 Pa. 232, 238 . . . .” Many other cases have likewise held that the doctrine of unclean hands applies only where the plaintiff’s wrongdoing directly affects the equitable relations existing between the parties: Robinson v. Goldberg, 331 Pa. 401 , 200 A. 4 ; Dales v. Muir, 351 Pa. 187 , 40 A. 2d 476 ; Goldberg v. Goldberg, 375 Pa. 78 , 99 A. 2d 474 ; Walacavage v. Walacavage, 168 Pa. Superior Ct. 334 , 77 A. 2d 723 .	2	1954–1963
WeCare Organics, LLC v. Zoning Hearing Bd. of Schuylkill County green pacommwct · 2008 1 sentence 2024Id.	1	2024–2024
Belleville v. David Cutler Group green pacommwct · 2015 2 sentences 2024Under the doctrine of unclean hands, a court may deprive a party of equitable relief when that party “is guilty of bad conduct relating to the matter at issue.” Belleville, 118 A.3d at 1199 (quoting Terraciano v. Dep’t of Transp., Bureau of Driver Licensing, 753 A.2d 233, 237-38 (Pa. 2000)). 2024More specifically, this doctrine “‘requires that one seeking equity act fairly and without fraud or deceit as to the controversy in issue.’” Belleville, 118 A.3d at 1199 (quoting Terraciano, 753 A.2d at 238 ).	1	2024–2024
Messenger v. Anderson green scotus · 1912 2 sentences 2017We think the more apt legal principles are those of law of the case and equitable estoppel. 7 The law of the case doctrine “expresses the practice of courts generally to refuse to reopen what has been decided.” Messenger v. Anderson, 225 U.S. 436, 444 , 32 S.Ct. 739 , 56 L.Ed. 1152 (1912) (Holmes, J.). 2017We think the more apt legal principles are those of law of the case and equitable estoppel. 7 The law of the case doctrine “expresses the practice of courts generally to refuse to reopen what has been decided.” Messenger v. Anderson, 225 U.S. 436, 444 , 32 S.Ct. 739 , 56 L.Ed. 1152 (1912) (Holmes, J.).	1	2017–2017
Morgan v. Richter green pacommwct · 1999 1 sentence 2017Id. 3 The Club argues that the trial court’s order can be sustained regardless of the merits of Muller’s arguments on the ground that Muller is barred from relief by the doctrine of unclean hands.	1	2017–2017
Armstrong School District v. Armstrong Education Ass'n green pa · 1991 1 sentence 2016Ass’n, 595 A.2d 1139 , 1141 n.2 (Pa. 1991). 18 Appellant Municipalities further assert that the trial court erred because it did not bar or limit Appellee Municipalities’ recovery based on the unclean hands doctrine, given Appellee Municipalities’ failure to reconcile their receipts of earned income tax revenue as statutorily required.	1	2016–2016
In re Bosley green pasuperct · 2011 2 sentences 2014The unclean hands doctrine derives “from the unwillingness of a court to give relief to a suitor who has so conducted himself as to shock the moral sensibilities of the judge, and it has noth ing to do "with the rights or liabilities of the parties.” Bosley, supra, 26 A.3d at 1114 (citing Estate of Pedrick, 505 Pa. 580 , 482 A.2d 215, 222 (1984)). 2014The unclean hands doctrine derives “from the unwillingness of a court to give relief to a suitor who has so conducted himself as to shock the moral sensibilities of the judge, and it has noth ing to do "with the rights or liabilities of the parties.” Bosley, supra, 26 A.3d at 1114 (citing Estate of Pedrick, 505 Pa. 580 , 482 A.2d 215, 222 (1984)).	1	2014–2014
Hung Tang v. Ho Yong Hwang green paed · 1992 1 sentence 2004Tang v. Hwang, 799 F. Supp. 499 (USDC, E.D.	1	2004–2004
Nacrelli v. Nacrelli green pa · 1926	1	1971–1971
Holst v. Butler green pa · 1954	1	1963–1963
Comstock v. Thompson green pa · 1926	1	1963–1963
Hartman v. Cohn green pa · 1944	1	1963–1963

Where else courts name it

CA 160 (1943–2026) TX 57 (1978–2026) CT 56 (1990–2025) NY 55 (1959–2025) NJ 44 (1932–2026) DE 42 (1934–2026) PA 41 (1954–2026) IL 40 (1947–2025) TN 35 (1924–2026) IN 34 (1994–2025) MI 31 (2015–2025) MS 30 (1987–2025) FL 26 (1957–2024) MD 23 (1968–2017) OH 23 (1998–2026) GA 19 (1963–2020) ID 15 (1985–2026) SC 15 (2001–2026) AL 12 (1968–2025) MN 12 (1977–2024) OR 12 (1972–2021) KY 12 (1952–2025) AZ 11 (1961–2022) MO 11 (2002–2024) NE 11 (1989–2019) VA 11 (1998–2026) NM 11 (1995–2023) AR 10 (1987–2026) UT 9 (2004–2024) WA 8 (1996–2024) NC 7 (1979–2018) CO 7 (2010–2025) LA 7 (1991–2023) KS 6 (1976–2022) NV 6 (2008–2021) MA 6 (1973–2015) DC 6 (1985–2026) AK 5 (2013–2024) ND 5 (1987–2025) HI 5 (1998–2024) IA 5 (1992–2023) ME 4 (1995–2018) RI 3 (1983–2009) VT 3 (2002–2025) WV 3 (1996–2020) WI 3 (1984–2021) SD 2 (2006–2015) MT 2 (2002–2020) NH 2 (1999–2016) OK 2 (1999–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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