unclean hands doctrine in California

2025(See Kendall-Jackson Winery, Ltd. v. Superior Court (1999) 76 Cal.App.4th 970, 979 [“Whether the particular misconduct is a bar to the alleged claim for relief depends on (1) analogous case law, (2) the nature of the misconduct, and (3) the relationship of the misconduct to the claimed injuries.”]; see also Dickson, Carlson & Campillo v. Pole (2000) 83 Cal.App.4th 436, 447 [“Whether the defense applies in particular circumstances depends on the analogous case law, the nature of the misconduct, and the relationship of the misconduct to the claimed injuries.”].) Because Defendants fail to discus

2025“The doctrine of unclean hands is a defense to an equitable action” that “rests on the maxim that ‘“‘he who comes into equity must come with clean 10 hands.’”’” (Aguayo v. Amaro (2013) 213 Cal.App.4th 1102, 1110 .) Although “[n]ot every wrongful act constitutes unclean hands,” “conduct that violates conscience, or good faith, or other equitable standards of conduct is sufficient cause to invoke the doctrine.” (Kendall-Jackson Winery, Ltd. v. Superior Court (1999) 76 Cal.App.4th 970, 979 .) To bar relief, however, “[t]he misconduct that brings the unclean hands doctrine into play” must be “conn

2023Accordingly, relief is not denied because the plaintiff may have acted improperly in the past or because such prior misconduct may indirectly affect the problem before the court.” (Fibreboard Paper Products Corp. v. 11 East Bay Union of Machinists (1964) 227 Cal.App.2d 675 , 728–729 (Fibreboard Paper).) As a threshold matter, plaintiffs contend the doctrine of unclean hands is not a defense to partition as a matter of law because the partition statutes refer only to a valid waiver as barring the right of partition.

2022The doctrine must be pleaded or called to the attention of the trial court in order that it may pass on the defense and also to permit the person against whom it is sought to be applied the opportunity to present such evidence as might bear on that issue.” (Fibreboard Paper Products Corp. v. East Bay Union of Machinists (1964) 227 Cal.App.2d 675 , 726– 727.) In his opening brief McNeal presents no cogent recitation of the evidence with citations to the record or legal analysis challenging the court’s application of the unclean hands doctrine.

2025(Id. at p. 621.) The Court of Appeal concluded that “Burroughs’s conversion and Unilogic’s misconduct occurred in the same transaction that forms the subject of this litigation—the joint development project.” (Ibid.) This was “enough to trigger application of the unclean hands doctrine.” (Ibid.) Other courts have similarly concluded that the unclean hands doctrine is applicable where the misconduct and cause of action relate to the same “transaction.” (See, e.g., Padideh, supra, 89 Cal.App.5th at p. 450 [third prong was met because the misconduct “occurred in a transaction or matter directly r

2023(Germo, supra, 107 Cal.App. at p. 543 .) Likewise, “[t]he determination of 34 whether the unclean hands defense applies ‘cannot be distorted into a proceeding to try the general morals of the parties.’ (Kendall-Jackson, supra, 76 Cal.App.4th at p. 979 .) ‘The issue is not that the plaintiff’s hands are dirty, but rather “ ‘ “that the manner of dirtying renders inequitable the assertion of such rights against the defendant.” ’ ” ’ [Citation.]” (Meridian, supra, 67 Cal.App.5th at pp. 685–686.) “ ‘A person is not placed forever entirely outside the protection of the law in a particular transactio

2025(Unilogic, supra, 10 Cal.App.4th at p. 621 .) For all of the reasons above, we conclude that Quality has raised triable issues of material fact as to the application of the unclean hands doctrine to RML’s claim, thus precluding summary judgment.

2025(Camp v. Jeffer, Mangles, Butler & Marmaro (1995) 35 Cal.App.4th 620, 638 ; see also Unilogic, Inc. v. Burroughs Corp. (1992) 10 Cal.App.4th 612, 620 .) The unclean hands doctrine protects not only parties’ interests, but also the courts’ interests.

2025(See Kendall-Jackson Winery, Ltd. v. Superior Court (1999) 76 Cal.App.4th 970, 979 [“Whether the particular misconduct is a bar to the alleged claim for relief depends on (1) analogous case law, (2) the nature of the misconduct, and (3) the relationship of the misconduct to the claimed injuries.”]; see also Dickson, Carlson & Campillo v. Pole (2000) 83 Cal.App.4th 436, 447 [“Whether the defense applies in particular circumstances depends on the analogous case law, the nature of the misconduct, and the relationship of the misconduct to the claimed injuries.”].) Because Defendants fail to discus

2025(See Kendall-Jackson Winery, Ltd. v. Superior Court (1999) 76 Cal.App.4th 970, 979 [“Whether the particular misconduct is a bar to the alleged claim for relief depends on (1) analogous case law, (2) the nature of the misconduct, and (3) the relationship of the misconduct to the claimed injuries.”]; see also Dickson, Carlson & Campillo v. Pole (2000) 83 Cal.App.4th 436, 447 [“Whether the defense applies in particular circumstances depends on the analogous case law, the nature of the misconduct, and the relationship of the misconduct to the claimed injuries.”].) Because Defendants fail to discus

2024(Blain v. Doctor’s Co. (1990) 222 Cal.App.3d 1048, 1060 .) Here, Phipps identifies no misconduct on Greer’s part, let alone explains how her misconduct caused him to be harmed, and he cites no analogous case law to support an unclean hands defense in this case.

2023Blain contends that in these circumstances, he has stated a [legal-malpractice] cause of action on the 21 theory that defense counsel’s improper strategy exposed him to greater liability, caused him emotional distress, and precluded his further work as a physician.” (Ibid.) The court first generally discussed the doctrine of unclean hands, observing that it was composed of not one “but a number of disparate doctrines, dependent for their substance upon the context of application.” (Blain, supra, 222 Cal.App.3d at p. 1059 , italics added.) After noting that the doctrine applied in both equitabl

2024He must come into court with clean hands, and keep them clean, or he will be denied relief, regardless of the merits of his claim.’ [Citation.] The doctrine of unclean hands requires unconscionable, bad faith, or inequitable conduct by the plaintiff in connection with the matter in controversy. [Citations.] Unclean hands applies when it would be inequitable to provide the plaintiff any relief, and provides a complete defense to both legal and equitable causes of action.” (Fladeboe v. American Isuzu Motors Inc. (2007) 150 Cal.App.4th 42, 56 .) “Whether the unclean hands doctrine can be applied

2022He must come into court with clean hands, and keep them clean, or he will be denied relief, regardless of the merits of his claim.’ [Citation.] The doctrine of unclean hands requires unconscionable, bad faith, or inequitable conduct by the [party] in connection with the matter in controversy. [Citations.] Unclean hands applies when it would be inequitable to provide [the party] any relief, and provides a complete defense to both legal and equitable causes of action.” (Fladeboe v. American Isuzu Motors Inc. (2007) 150 Cal.App.4th 42, 56 .) “Whether the unclean hands doctrine applies turns on th

2024To the extent there are unclean hands here, they belong equally to Sack, Pinner, Johnny, and Griffin.” In their opening brief, Griffin and PCC do not address the three-pronged test used by courts to determine the effect to be given to a plaintiff’s purported “unclean hands conduct.” (Jay Bharat Developers, Inc. v. Minidis, supra, 167 Cal.App.4th at p. 445 .) Instead, they argue: “The trial court’s conclusion that an unclean hands defense could not prevail if the participants were equally culpable turns the well-settled principle of in pari delicto on its head.

2023(See e.g., Brown v. Grimes (2011) 192 Cal.App.4th 265, 275 (Brown) [concluding doctrine inapplicable on de novo review based on application of three-pronged Blain test and declining to decide standard of review “of an unclean hands determination if the doctrine” were applicable], citing Jay Bharat Developers, Inc. v. Minidis (2008) 167 Cal.App.4th 437 , 445–446 (Jay Bharat) [applying three-pronged Blain test on appeal from preliminary injunction order in fraudulent-inducement case].) Although Brown and the parties here cite Jay Bharat for the proposition that whether the unclean-hands defense

2024He must come into court with clean hands, and keep them clean, or he will be denied relief, regardless of the merits of his claim.’ [Citation.] The doctrine of unclean hands requires unconscionable, bad faith, or inequitable conduct by the plaintiff in connection with the matter in controversy. [Citations.] Unclean hands applies when it would be inequitable to provide the plaintiff any relief, and provides a complete defense to both legal and equitable causes of action.” (Fladeboe v. American Isuzu Motors Inc. (2007) 150 Cal.App.4th 42, 56 .) “Whether the unclean hands doctrine can be applied

2023(See e.g., Brown v. Grimes (2011) 192 Cal.App.4th 265, 275 (Brown) [concluding doctrine inapplicable on de novo review based on application of three-pronged Blain test and declining to decide standard of review “of an unclean hands determination if the doctrine” were applicable], citing Jay Bharat Developers, Inc. v. Minidis (2008) 167 Cal.App.4th 437 , 445–446 (Jay Bharat) [applying three-pronged Blain test on appeal from preliminary injunction order in fraudulent-inducement case].) Although Brown and the parties here cite Jay Bharat for the proposition that whether the unclean-hands defense

2021Moreover, the doctrine of unclean hands “ ‘is an equitable rationale for refusing a plaintiff relief where principles of fairness dictate that the plaintiff should not recover, regardless of the merits of his claim.’ ” (Mendoza v. Ruesga (2008) 169 Cal.App.4th 270, 279 .) The trial court did not find that Hakenjos Hall had unclean hands and Schwartz has not established that the court abused its discretion in this regard.

2015(See, e.g., Mendoza v. Ruesga (2008) 169 Cal.App.4th 270, 279 [holding as a matter of law unclean hands defense does not apply].) Here because there is no analogous case applying the doctrine of unclean hands as a defense to an action pursuant to section 7107 the doctrine can be determined as a matter of law. 19 Not only is there no analogous case applying the doctrine to an action pursuant to section 7107, there are analogous cases holding as a matter of law that the doctrine does not apply to such statutory causes of action.

2025(Camp v. Jeffer, Mangles, Butler & Marmaro (1995) 35 Cal.App.4th 620, 638 ; see also Unilogic, Inc. v. Burroughs Corp. (1992) 10 Cal.App.4th 612, 620 .) The unclean hands doctrine protects not only parties’ interests, but also the courts’ interests.

2021Co. v. Automotive Maintenance Machinery Co. (1945) 324 U.S. 806 (Precision): “[the unclean hands doctrine] is 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.” (Id. at p. 814, italics added; see also Thomas v. Gordon (2000) 85 Cal.App.4th 113, 123 [quoting Precision]; Camp v. Jeffer, Mangels, Butler & Marmaro (1995) 35 Cal.App.4th 620, 638 [same]; Burton v. Sosinsky (1988) 203 Cal.App.3d 562 , 573–574 [same].) Defenda

2021(Carman v. Athearn (1947) 77 Cal.App.2d 585, 598 [“The misconduct must infect the cause of action before the court.”]; Brown v. Grimes, supra, 192 Cal.App.4th at p. 283 [“ ‘[the] misconduct [of the plaintiff] must be so intimately connected to the injury of another with the matter for which he seeks relief, as to make it inequitable to accord him such relief’ ”].) Finally, Menefee has not cited any authorities that persuade us that the unclean hands defense applies here.

2011(E.g., Brown, supra, 192 Cal.App.4th at p. 283 [“The unclean hands emanating from the Brown-Ross agreement did not directly affect or infect the relationship between Grimes and Brown and, most importantly, was not inequitable conduct towards Grimes.”]; Peregrine Funding, Inc. v. Sheppard Mullin Richter & Hampton LLP (2005) 133 Cal.App.4th 658, 680 [ 35 Cal.Rptr.3d 31 ] [“It has long been held that the misconduct asserted in an unclean hands defense must be sufficiently related to the matter currently before the court.”]; Kendall-Jackson Winery, Ltd. v. Superior Court (1999) 76 Cal.App.4th 970,

2023In that vein, in Kendall-Jackson, a malicious prosecution case, the court addressed this first prong of the unclean-hands doctrine by discussing two prior malicious prosecution cases that had applied the doctrine as a bar to recovery— Pond v. Insurance Co. of North America (1984) 151 Cal.App.3d 280 , 284–285, 291 (Pond), and DeRosa v. Transamerica Title Ins.

2023(Kendall-Jackson, supra, 76 Cal.App.4th at p. 980 ; Pond, supra, 151 Cal.App.3d at pp. 286, 290.) According to the Pond court, the undisclosed information “if timely disclosed, may well have changed the outcome of the [underlying] indemnity action.” (Pond, supra, 151 Cal.App.3d at p. 291 .) The Pond court affirmed summary judgment in favor of the insurer, applying the unclean- hands defense to bar Pond’s recovery for malicious prosecution.

2023(Kendall-Jackson, supra, 76 Cal.App.4th at p. 981 ; DeRosa, supra, 213 Cal.App.3d at pp. 1393–1395.) Transamerica raised the unclean-hands defense and moved for summary judgment.

2023(Ibid.; DeRosa, supra, 213 Cal.App.3d at pp. 1395–1396.) As discussed in Kendall-Jackson, the DeRosa court “rejected DeRosa’s argument that the malicious prosecution action was unrelated to his conduct in assisting [his buyer] to defraud his creditors and, therefore, the unclean hands doctrine should not apply.

2014(Cortez v. Purolator Air Filtration Products Co. (2000) 23 Cal.4th 163, 179 .) The underlying rationales of the cases cited are similar: the antitrust laws are best served by insuring that a private action is a constant threat to deter anyone contemplating business behavior in violation of the antitrust laws (Perma Mufflers v. Int’l Parts Corp., supra, 392 U.S. at p. 139 ) and permitting an unclean hands defense would judicially sanction a defendant who engaged in an act declared by statute to be void or against public policy (Ticconi v. Blue Shield of California Life & Health Ins.

2008(Cortez, supra, 23 Cal.4th at p. 169 .) Without discussing the particular alleged wrongdoing of the plaintiff, our Supreme Court held a defendant may not use the unclean hands doctrine to defeat a UCL claim, although the court may consider the equities in fashioning a remedy under the UCL. ( 23 Cal.4th at p. 179 .) Justice Werdegar explained in her concurring opinion that, “in general, as between a person who is enriched as the result of his or her violation of the law, and a person intended to be protected by the law who is harmed by its violation, for the violator to retain the benefit would

2004The unclean hands doctrine does not apply if the inequitable conduct did not occur in the transaction to which the relief sought relates. ( Pepper v. Superior Court (1977) 76 Cal.App.3d 252, 259 , 142 Cal.Rptr. 759 .) The alleged inequitable conduct here did not relate directly to the *299 withdrawing partners' capital accounts.

2004The unclean hands doctrine does not apply if the inequitable conduct did not occur in the transaction to which the relief sought relates. ( Pepper v. Superior Court (1977) 76 Cal.App.3d 252, 259 , 142 Cal.Rptr. 759 .) The alleged inequitable conduct here did not relate directly to the *299 withdrawing partners' capital accounts.

2025Although the conduct of a corporation’s agent is generally imputed to the corporation (Uecker v. Zentil (2016) 244 Cal.App.4th 789, 797 (Uecker); Peregrine Funding, Inc. v. Sheppard Mullin Richter & Hampton LLP (2005) 133 Cal.App.4th 658, 679 (Peregrine)), California law provides that “[a]n agent can never have authority . . . to do an act which is . . . a fraud upon the principal” (Civ.

2025Although the conduct of a corporation’s agent is generally imputed to the corporation (Uecker v. Zentil (2016) 244 Cal.App.4th 789, 797 (Uecker); Peregrine Funding, Inc. v. Sheppard Mullin Richter & Hampton LLP (2005) 133 Cal.App.4th 658, 679 (Peregrine)), California law provides that “[a]n agent can never have authority . . . to do an act which is . . . a fraud upon the principal” (Civ.

2022Because the al-Jarallahs were “‘not guilty of inequitable conduct toward’” Kandeel in their investment with him, their “‘hands are as clean as the court can require.’” (Brown, supra, 192 Cal.App.4th at p. 283 ; Martin, supra, 145 Cal.App.3d at p. 239, fn. 1 ; Mattco, supra, 52 Cal.App.4th at p. 846 ; see also, Jay Bharat Developers, Inc. v. Minidis (2008) 167 Cal.App.4th 437, 445 , quoting Kendall-Jackson, supra, 76 Cal.App.4th at p. 979 [“‘The misconduct must “‘“prejudicially affect . . . the rights of the person against whom the relief is sought so that it would be inequitable to grant such

2022Because the al-Jarallahs were “‘not guilty of inequitable conduct toward’” Kandeel in their investment with him, their “‘hands are as clean as the court can require.’” (Brown, supra, 192 Cal.App.4th at p. 283 ; Martin, supra, 145 Cal.App.3d at p. 239, fn. 1 ; Mattco, supra, 52 Cal.App.4th at p. 846 ; see also, Jay Bharat Developers, Inc. v. Minidis (2008) 167 Cal.App.4th 437, 445 , quoting Kendall-Jackson, supra, 76 Cal.App.4th at p. 979 [“‘The misconduct must “‘“prejudicially affect . . . the rights of the person against whom the relief is sought so that it would be inequitable to grant such

2021(Russell v. Soldinger (1976) 59 Cal.App.3d 633, 645-646 (Russell) [affirming nonsuit on opening statement based on doctrine of unclean hands]; Abeyta v. Superior Court (1993) 17 Cal.App.4th 1037, 1041 [Nonsuit at this early stage may “only be upheld on appeal if, after accepting all the asserted facts as true and indulging every legitimate inference in favor of plaintiff, it can be said those facts and inferences lead inexorably to the conclusion plaintiff cannot establish an essential element of its cause of action or has inadvertently established incontrovertible proof of an affirmative defe

2015(Russell v. Soldinger (1976) 59 Cal.App.3d 633, 645-646 [affirming nonsuit on opening statement 8 based on doctrine of unclean hands].) Plaintiffs’ counsel during his opening statement told the jury that plaintiffs knew the documents they signed and submitted to the Franchise Tax Board were falsely backdated, facts constituting defendants’ unclean hands defense.

2025“The doctrine of unclean hands is a defense to an equitable action” that “rests on the maxim that ‘“‘he who comes into equity must come with clean 10 hands.’”’” (Aguayo v. Amaro (2013) 213 Cal.App.4th 1102, 1110 .) Although “[n]ot every wrongful act constitutes unclean hands,” “conduct that violates conscience, or good faith, or other equitable standards of conduct is sufficient cause to invoke the doctrine.” (Kendall-Jackson Winery, Ltd. v. Superior Court (1999) 76 Cal.App.4th 970, 979 .) To bar relief, however, “[t]he misconduct that brings the unclean hands doctrine into play” must be “conn

2025“The doctrine of unclean hands is a defense to an equitable action” that “rests on the maxim that ‘“‘he who comes into equity must come with clean 10 hands.’”’” (Aguayo v. Amaro (2013) 213 Cal.App.4th 1102, 1110 .) Although “[n]ot every wrongful act constitutes unclean hands,” “conduct that violates conscience, or good faith, or other equitable standards of conduct is sufficient cause to invoke the doctrine.” (Kendall-Jackson Winery, Ltd. v. Superior Court (1999) 76 Cal.App.4th 970, 979 .) To bar relief, however, “[t]he misconduct that brings the unclean hands doctrine into play” must be “conn

2025Unclean Hands Defendants also contend the trial court abused its discretion in declining to apply the doctrine of unclean hands, which requires a plaintiff in an equitable action to “come into court with clean hands,” or “be denied relief, 12 regardless of the merits of [the] claim.” (Aguayo v. Amaro (2013) 213 Cal.App.4th 1102, 1110 (Aguayo).) The unclean hands defense applies only if the inequitable conduct “occur[red] in the transaction to which the relief sought relates.” (O’Flaherty v. Belgum (2004) 115 Cal.App.4th 1044, 1060 .) That is, the connection between “ ‘the misconduct and the cl

2025Unclean Hands Defendants also contend the trial court abused its discretion in declining to apply the doctrine of unclean hands, which requires a plaintiff in an equitable action to “come into court with clean hands,” or “be denied relief, 12 regardless of the merits of [the] claim.” (Aguayo v. Amaro (2013) 213 Cal.App.4th 1102, 1110 (Aguayo).) The unclean hands defense applies only if the inequitable conduct “occur[red] in the transaction to which the relief sought relates.” (O’Flaherty v. Belgum (2004) 115 Cal.App.4th 1044, 1060 .) That is, the connection between “ ‘the misconduct and the cl

2025(See generally Salas v. Sierra Chemical Co. (2014) 59 Cal.4th 407, 432 [describing “the equitable doctrine of unclean hands”].) In February 2017, the trial court, in another case initiated by U.S. Bank, ordered U.S. Bank to provide an accurate “payoff/reinstatement statement” within two days.

2017Unclean Hands Finally, the County argues that the court erred in finding plaintiff demonstrated a probability of prevailing because her unclean hands were a *368 complete defense, where plaintiff disclosed confidential information to an unauthorized person. "[T]he equitable doctrine of unclean hands applies when a plaintiff has acted unconscionably, in bad faith, or inequitably in the matter in which the plaintiff seeks relief." ( Salas v. Sierra Chemical Co. (2014) 59 Cal.4th 407 , 432, 173 Cal.Rptr.3d 689 , 327 P.3d 797 .) The unclean hands defense can serve as a defense to employment-based

2023For example, in Jay Bharat, the court’s discussion of this prong of the Blaine test was limited to this: “As for analogous case law, courts have concluded that injunctive relief is appropriate where a terminated franchisee continues to use a franchisor’s trademark. [Citations.]” (Jay Bharat, supra, 167 Cal.App.4th at p. 446 .) Similarly, but presenting the converse, in rejecting the 26 application of the unclean-hands doctrine, the court in CrossTalk said only: “Defendant has cited no authority finding unclean hands generally to be a defense to claims for extortion or ‘economic duress’ in othe

2015Blain, supra, . . . at p. 1060; accord, Unilogic, Inc. v. Burroughs Corp. (1992) 10 Cal.App.4th 612, 618-621 ; CrossTalk Productions, supra, [at pp. 641- 643]. [¶] FTR contends, and the District concedes, that there is no analogous case law supporting the application of the unclean hands defense to the facts present here.

2022Because the al-Jarallahs were “‘not guilty of inequitable conduct toward’” Kandeel in their investment with him, their “‘hands are as clean as the court can require.’” (Brown, supra, 192 Cal.App.4th at p. 283 ; Martin, supra, 145 Cal.App.3d at p. 239, fn. 1 ; Mattco, supra, 52 Cal.App.4th at p. 846 ; see also, Jay Bharat Developers, Inc. v. Minidis (2008) 167 Cal.App.4th 437, 445 , quoting Kendall-Jackson, supra, 76 Cal.App.4th at p. 979 [“‘The misconduct must “‘“prejudicially affect . . . the rights of the person against whom the relief is sought so that it would be inequitable to grant such

2022Because the al-Jarallahs were “‘not guilty of inequitable conduct toward’” Kandeel in their investment with him, their “‘hands are as clean as the court can require.’” (Brown, supra, 192 Cal.App.4th at p. 283 ; Martin, supra, 145 Cal.App.3d at p. 239, fn. 1 ; Mattco, supra, 52 Cal.App.4th at p. 846 ; see also, Jay Bharat Developers, Inc. v. Minidis (2008) 167 Cal.App.4th 437, 445 , quoting Kendall-Jackson, supra, 76 Cal.App.4th at p. 979 [“‘The misconduct must “‘“prejudicially affect . . . the rights of the person against whom the relief is sought so that it would be inequitable to grant such

2025(See Mendoza v. Ruesga (2008) 169 Cal.App.4th 270, 282-283 [declining to apply unclean hands defense when doing so would 14 undermine a statute aimed at protecting people from unscrupulous immigration consultants]; Carter v. Cohen (2010) 188 Cal.App.4th 1038, 1050 [declining to apply unclean hands defense when doing so would undermine a rental control ordinance barring excessive rent charges]; East West Bank v. Rio School Dist. (2015) 235 Cal.App.4th 742, 744-745 [declining to apply unclean hands defense when doing so would undermine a public contracting statute]; Ticconi v. Blue Shield of Cal

2025(See Mendoza v. Ruesga (2008) 169 Cal.App.4th 270, 282-283 [declining to apply unclean hands defense when doing so would 14 undermine a statute aimed at protecting people from unscrupulous immigration consultants]; Carter v. Cohen (2010) 188 Cal.App.4th 1038, 1050 [declining to apply unclean hands defense when doing so would undermine a rental control ordinance barring excessive rent charges]; East West Bank v. Rio School Dist. (2015) 235 Cal.App.4th 742, 744-745 [declining to apply unclean hands defense when doing so would undermine a public contracting statute]; Ticconi v. Blue Shield of Cal

2024The real interest is effectively 80%.” The trial court exercised its discretion properly when it found these efforts to conceal the deal’s terms barred “any award in equity.” (See Burton v. Sosinsky (1988) 203 Cal.App.3d 562, 573 [doctrine of unclean hands “‘is a self-imposed ordinance that closes the doors of a court of equity to one tainted with inequitableness or bad faith 18 relative to the matter in which he seeks relief, however improper may have been the behavior of the defendant’”].)3 DISPOSITION Judgment is affirmed.

2021Co. v. Automotive Maintenance Machinery Co. (1945) 324 U.S. 806 (Precision): “[the unclean hands doctrine] is 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.” (Id. at p. 814, italics added; see also Thomas v. Gordon (2000) 85 Cal.App.4th 113, 123 [quoting Precision]; Camp v. Jeffer, Mangels, Butler & Marmaro (1995) 35 Cal.App.4th 620, 638 [same]; Burton v. Sosinsky (1988) 203 Cal.App.3d 562 , 573–574 [same].) Defenda

2026(See DeGarmo v. 8 Goldman (1942) 19 Cal.2d 755, 764-765 ; Rosenfeld v. Zimmer (1953) 116 Cal.App.2d 719, 723 ; see also, e.g., Sirott v. Superior Court (2022) 78 Cal.App.5th 371 , 380.) Zhu argues that Yang’s unclean hands defense lacks merit in any event because the wrongdoing Yang alleges is not sufficiently related to Zhu’s claim.

2000It stated that the doctrine of unclean hands “differs from the maxim ‘he who seeks equity must do equity’ in that the latter assumes that different equitable rights have arisen from the same subject matter or transaction, some in favor of plaintiff and some in favor of the defendant so that the plaintiff is required to recognize and provide for defendant’s rights and his relief is granted only upon a showing that defendant’s rights are protected.” (DeGarmo v. Goldman, supra, 19 Cal.2d at p. 765 .) 7 The defense of unclean hands does not apply in every instance where the plaintiff has committed