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25 Maryland opinions name it 2 courts 1952–2023 3 in the last five years
The cases below were cited by Maryland 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.
| Case | Followed | Cited |
|---|---|---|
Adams v. Manowngreen2 sentences2019For that reason, "an important element of the clean hands doctrine is that the *76 alleged misconduct must be connected with the transaction upon which the claimant seeks relief." Id. at 475 , 615 A.2d 611 . 2019For that reason, "an important element of the clean hands doctrine is that the *76 alleged misconduct must be connected with the transaction upon which the claimant seeks relief." Id. at 475 , 615 A.2d 611 . | 4 | 11 |
Hicks v. Gilbertgreen2 sentences2017The clean hands doctrine states that “courts of equity will not lend their aid to anyone seeking their active interposition, who has been guilty of fraudulent, illegal, or inequitable conduct in the matter with relation to which he seeks assistance.” Hlista, 239 Md. at 48 , 210 A.2d at 156 ; see also Hicks v. Gilbert, 135 Md.App. 394, 400 , 762 A.2d 986, 989-90 (2000). 2017The clean hands doctrine states that “courts of equity will not lend their aid to anyone seeking their active interposition, who has been guilty of fraudulent, illegal, or inequitable conduct in the matter with relation to which he seeks assistance.” Hlista, 239 Md. at 48 , 210 A.2d at 156 ; see also Hicks v. Gilbert, 135 Md.App. 394, 400 , 762 A.2d 986, 989-90 (2000). | 3 | 4 |
Mona v. Mona Electric Group, Inc.green2 sentences2023Grp., Inc., 176 Md. 2023Grp., Inc., 176 Md. | 3 | 3 |
Hlista v. Altevogtgreen2 sentences2017Therefore, the Court explained that the venerated equity doctrine of clean hands which requires that “he who comes into equity must come with clean hands,” Hlista v. Altevogt, 239 Md. 43, 48 , 210 A.2d 153, 156 (1965), is applicable in foreclosure proceedings such as the one implicated in the present case. 2017Therefore, the Court explained that the venerated equity doctrine of clean hands which requires that “he who comes into equity must come with clean hands,” Hlista v. Altevogt, 239 Md. 43, 48 , 210 A.2d 153, 156 (1965), is applicable in foreclosure proceedings such as the one implicated in the present case. | 3 | 3 |
Manown v. Adamsgreen2 sentences2007See Manown v. Adams, 89 Md.App. 503, 513 , 598 A.2d 821 (1991), reversed on other grounds, 328 Md. 463 , 615 A.2d 611 (1992). *714 In Turner v. Turner, 147 Md.App. 350, 419 , 809 A.2d 18 (2002), this Court summarized the clean hands doctrine as follows: The equitable doctrine of unclean hands is “designed to ‘prevent the court from assisting in fraud or other inequitable conduct____’ ” Gordon v. Posner, 142 Md.App. 399, 433 , 790 A.2d 675 (quoting Adams v. Manown, 328 Md. 463, 482 , 615 A.2d 611 (1992)), cert. denied, 369 Md. 180 , 798 A.2d 552 (2002). 2007See Manown v. Adams, 89 Md.App. 503, 513 , 598 A.2d 821 (1991), reversed on other grounds, 328 Md. 463 , 615 A.2d 611 (1992). *714 In Turner v. Turner, 147 Md.App. 350, 419 , 809 A.2d 18 (2002), this Court summarized the clean hands doctrine as follows: The equitable doctrine of unclean hands is “designed to ‘prevent the court from assisting in fraud or other inequitable conduct____’ ” Gordon v. Posner, 142 Md.App. 399, 433 , 790 A.2d 675 (quoting Adams v. Manown, 328 Md. 463, 482 , 615 A.2d 611 (1992)), cert. denied, 369 Md. 180 , 798 A.2d 552 (2002). | 1 | 5 |
Winmark Ltd. Partnership v. Miles & Stockbridgegreen2 sentences2006We stated as follows: "The policy underlying judicial estoppel and underlying the clean hands doctrine is the same. `The clean hands doctrine is not applied for the protection of the parties nor as a punishment to the wrongdoer; rather, the doctrine is intended to protect the courts from having to endorse or reward inequitable conduct.'" Id. (quoting Adams v. Manown, 328 Md. 463, 474-75 , 615 A.2d 611, 616 (1992)). 2006We stated as follows: “The policy underlying judicial estoppel and underlying the clean hands doctrine is the same. ‘The clean hands doctrine is not applied for the protection of the parties nor as a punishment to the wrongdoer; rather, the doctrine is intended to protect the courts from having to endorse or reward inequitable conduct.’ ” Id. (quoting Adams v. Manown, 328 Md. 463, 474-75 , 615 A.2d 611, 616 (1992)). | 1 | 5 |
Space Aero Products Co. v. R. E. Darling Co.green2 sentences1979The Husband complains additionally that the Wife came into court with “unclean hands.” The application of the clean hands doctrine rests in the sound discretion of the court and is applied “not for the protection of the parties, but for the court’s own protection.” Space Aero Products Co. v. Darling Co., 238 Md. 93, 120 , 208 A. 2d 74, 88 (1965). 1979The Husband complains additionally that the Wife came into court with “unclean hands.” The application of the clean hands doctrine rests in the sound discretion of the court and is applied “not for the protection of the parties, but for the court’s own protection.” Space Aero Products Co. v. Darling Co., 238 Md. 93, 120 , 208 A. 2d 74, 88 (1965). | 1 | 3 |
Wells Fargo Home Mortgage, Inc. v. Nealgreen2 sentences2020P’ship, 438 Md. 451, 479 (2014) (applying laches to equitable claims seeking to halt redevelopment project); Neal, 398 Md. at 729 (holding that “the venerated equity 12 doctrine of clean hands . . . is applicable in foreclosure proceedings”); Ross v. State Bd. of Elections, 387 Md. 649, 668 (2005) (holding that a petition seeking to invalidate an election “is barred as a matter of law by the common law doctrine of laches”); Ver Brycke v. Ver Brycke, 379 Md. 669, 703 (2004) (holding that in distinguishing whether an action sounds in law or in equity for purposes of identifying the applicable li 2009Relying on the clean hands doctrine, the Court explained that, while the plaintiff “may be said to be in default, the legal fiction that no default exists may be maintainable until such time as Wells Fargo complies with the statutory and regulatory imperative to pursue loss mitigation prior to foreclosure.” Id. at 730 , 922 A.2d 538 . | 1 | 2 |
Ver Brycke v. Ver Bryckegreen1 sentence2020P’ship, 438 Md. 451, 479 (2014) (applying laches to equitable claims seeking to halt redevelopment project); Neal, 398 Md. at 729 (holding that “the venerated equity 12 doctrine of clean hands . . . is applicable in foreclosure proceedings”); Ross v. State Bd. of Elections, 387 Md. 649, 668 (2005) (holding that a petition seeking to invalidate an election “is barred as a matter of law by the common law doctrine of laches”); Ver Brycke v. Ver Brycke, 379 Md. 669, 703 (2004) (holding that in distinguishing whether an action sounds in law or in equity for purposes of identifying the applicable li | 1 | 1 |
Ross v. State Board of Electionsgreen1 sentence2020P’ship, 438 Md. 451, 479 (2014) (applying laches to equitable claims seeking to halt redevelopment project); Neal, 398 Md. at 729 (holding that “the venerated equity 12 doctrine of clean hands . . . is applicable in foreclosure proceedings”); Ross v. State Bd. of Elections, 387 Md. 649, 668 (2005) (holding that a petition seeking to invalidate an election “is barred as a matter of law by the common law doctrine of laches”); Ver Brycke v. Ver Brycke, 379 Md. 669, 703 (2004) (holding that in distinguishing whether an action sounds in law or in equity for purposes of identifying the applicable li | 1 | 1 |
Schaeffer v. Anne Arundel Countygreen1 sentence2020P’ship, 438 Md. 451, 479 (2014) (applying laches to equitable claims seeking to halt redevelopment project); Neal, 398 Md. at 729 (holding that “the venerated equity 12 doctrine of clean hands . . . is applicable in foreclosure proceedings”); Ross v. State Bd. of Elections, 387 Md. 649, 668 (2005) (holding that a petition seeking to invalidate an election “is barred as a matter of law by the common law doctrine of laches”); Ver Brycke v. Ver Brycke, 379 Md. 669, 703 (2004) (holding that in distinguishing whether an action sounds in law or in equity for purposes of identifying the applicable li | 1 | 1 |
LaSalle Bank, N.A. v. Reevesgreen1 sentence2020P’ship, 438 Md. 451, 479 (2014) (applying laches to equitable claims seeking to halt redevelopment project); Neal, 398 Md. at 729 (holding that “the venerated equity 12 doctrine of clean hands . . . is applicable in foreclosure proceedings”); Ross v. State Bd. of Elections, 387 Md. 649, 668 (2005) (holding that a petition seeking to invalidate an election “is barred as a matter of law by the common law doctrine of laches”); Ver Brycke v. Ver Brycke, 379 Md. 669, 703 (2004) (holding that in distinguishing whether an action sounds in law or in equity for purposes of identifying the applicable li | 1 | 1 |
State Center, LLC v. Lexington Charles Ltd. Partnershipgreen1 sentence2020P’ship, 438 Md. 451, 479 (2014) (applying laches to equitable claims seeking to halt redevelopment project); Neal, 398 Md. at 729 (holding that “the venerated equity 12 doctrine of clean hands . . . is applicable in foreclosure proceedings”); Ross v. State Bd. of Elections, 387 Md. 649, 668 (2005) (holding that a petition seeking to invalidate an election “is barred as a matter of law by the common law doctrine of laches”); Ver Brycke v. Ver Brycke, 379 Md. 669, 703 (2004) (holding that in distinguishing whether an action sounds in law or in equity for purposes of identifying the applicable li | 1 | 1 |
Mitchell v. Yackogreen1 sentence2020P’ship, 438 Md. 451, 479 (2014) (applying laches to equitable claims seeking to halt redevelopment project); Neal, 398 Md. at 729 (holding that “the venerated equity 12 doctrine of clean hands . . . is applicable in foreclosure proceedings”); Ross v. State Bd. of Elections, 387 Md. 649, 668 (2005) (holding that a petition seeking to invalidate an election “is barred as a matter of law by the common law doctrine of laches”); Ver Brycke v. Ver Brycke, 379 Md. 669, 703 (2004) (holding that in distinguishing whether an action sounds in law or in equity for purposes of identifying the applicable li | 1 | 1 |
Buxton v. Buxtongreen1 sentence2020P’ship, 438 Md. 451, 479 (2014) (applying laches to equitable claims seeking to halt redevelopment project); Neal, 398 Md. at 729 (holding that “the venerated equity 12 doctrine of clean hands . . . is applicable in foreclosure proceedings”); Ross v. State Bd. of Elections, 387 Md. 649, 668 (2005) (holding that a petition seeking to invalidate an election “is barred as a matter of law by the common law doctrine of laches”); Ver Brycke v. Ver Brycke, 379 Md. 669, 703 (2004) (holding that in distinguishing whether an action sounds in law or in equity for purposes of identifying the applicable li | 1 | 1 |
Turner v. Turnergreen2 sentences2007See Manown v. Adams, 89 Md.App. 503, 513 , 598 A.2d 821 (1991), reversed on other grounds, 328 Md. 463 , 615 A.2d 611 (1992). *714 In Turner v. Turner, 147 Md.App. 350, 419 , 809 A.2d 18 (2002), this Court summarized the clean hands doctrine as follows: The equitable doctrine of unclean hands is “designed to ‘prevent the court from assisting in fraud or other inequitable conduct____’ ” Gordon v. Posner, 142 Md.App. 399, 433 , 790 A.2d 675 (quoting Adams v. Manown, 328 Md. 463, 482 , 615 A.2d 611 (1992)), cert. denied, 369 Md. 180 , 798 A.2d 552 (2002). 2007See Manown v. Adams, 89 Md.App. 503, 513 , 598 A.2d 821 (1991), reversed on other grounds, 328 Md. 463 , 615 A.2d 611 (1992). *714 In Turner v. Turner, 147 Md.App. 350, 419 , 809 A.2d 18 (2002), this Court summarized the clean hands doctrine as follows: The equitable doctrine of unclean hands is “designed to ‘prevent the court from assisting in fraud or other inequitable conduct____’ ” Gordon v. Posner, 142 Md.App. 399, 433 , 790 A.2d 675 (quoting Adams v. Manown, 328 Md. 463, 482 , 615 A.2d 611 (1992)), cert. denied, 369 Md. 180 , 798 A.2d 552 (2002). | 1 | 1 |
Schaeffer v. Sterlinggreen2 sentences1992In addition, in the case of Schaeffer v. Sterling, 176 Md. 553 , 6 A.2d 254 (1939), we stated that when applying the clean hands doctrine an equity court “will leave [the complainant] to whatever remedies he may have at law.” Id. at 555 , 6 A.2d at 255 (emphasis added). 1992In addition, in the case of Schaeffer v. Sterling, 176 Md. 553 , 6 A.2d 254 (1939), we stated that when applying the clean hands doctrine an equity court “will leave [the complainant] to whatever remedies he may have at law.” Id. at 555 , 6 A.2d at 255 (emphasis added). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Niner v. Hanson
green
2 sentences1992In Niner, 217 Md. 298 , 142 A.2d 798 , the plaintiff sought to compel the carpenters’ union to recognize him as a member and to enjoin them from interfering with his membership. 1992In Niner, 217 Md. 298 , 142 A.2d 798 , the plaintiff sought to compel the carpenters’ union to recognize him as a member and to enjoin them from interfering with his membership. | 3 | 1965–1992 |
Gordon v. Posner
green
2 sentences2007See Manown v. Adams, 89 Md.App. 503, 513 , 598 A.2d 821 (1991), reversed on other grounds, 328 Md. 463 , 615 A.2d 611 (1992). *714 In Turner v. Turner, 147 Md.App. 350, 419 , 809 A.2d 18 (2002), this Court summarized the clean hands doctrine as follows: The equitable doctrine of unclean hands is “designed to ‘prevent the court from assisting in fraud or other inequitable conduct____’ ” Gordon v. Posner, 142 Md.App. 399, 433 , 790 A.2d 675 (quoting Adams v. Manown, 328 Md. 463, 482 , 615 A.2d 611 (1992)), cert. denied, 369 Md. 180 , 798 A.2d 552 (2002). 2007See Manown v. Adams, 89 Md.App. 503, 513 , 598 A.2d 821 (1991), reversed on other grounds, 328 Md. 463 , 615 A.2d 611 (1992). *714 In Turner v. Turner, 147 Md.App. 350, 419 , 809 A.2d 18 (2002), this Court summarized the clean hands doctrine as follows: The equitable doctrine of unclean hands is “designed to ‘prevent the court from assisting in fraud or other inequitable conduct____’ ” Gordon v. Posner, 142 Md.App. 399, 433 , 790 A.2d 675 (quoting Adams v. Manown, 328 Md. 463, 482 , 615 A.2d 611 (1992)), cert. denied, 369 Md. 180 , 798 A.2d 552 (2002). | 2 | 2006–2007 |
Keystone Driller Co. v. General Excavator Co.
green
2 sentences2007Thus, courts “are not bound by formula or restrained by any limitation that tends to trammel the free and just exercise of discretion.” Keystone Driller Co. v. General Excavator Co., 290 U.S. 240, 245-46 , 54 S.Ct. 146, 148 , 78 L.Ed. 293 (1933). 2007Thus, courts “are not bound by formula or restrained by any limitation that tends to trammel the free and just exercise of discretion.” Keystone Driller Co. v. General Excavator Co., 290 U.S. 240, 245-46 , 54 S.Ct. 146, 148 , 78 L.Ed. 293 (1933). | 1 | 2007–2007 |
Smith v. Cessna Aircraft Co.
green
2 sentences2007Its purpose is to “safeguard the judicial process.” Smith, supra, 124 F.R.D. at 106 . 2007Its purpose is to “safeguard the judicial process.” Smith, supra, 124 F.R.D. at 106 . | 1 | 2007–2007 |
New Hampshire v. Maine
green
2 sentences2006In both of those cases we referred to the Supreme Court’s analysis in New Hampshire v. Maine, 532 U.S. 742, 750-51 , 121 S.Ct. 1808, 1815 , 149 L.Ed.2d 968 (2001), which stated: Courts have observed that “[t]he circumstances under which judicial estoppel may appropriately be invoked are probably not reducible to any general formulation of principle,” Allen [v. Zurich Ins. 2006In both of those cases we referred to the Supreme Court’s analysis in New Hampshire v. Maine, 532 U.S. 742, 750-51 , 121 S.Ct. 1808, 1815 , 149 L.Ed.2d 968 (2001), which stated: Courts have observed that “[t]he circumstances under which judicial estoppel may appropriately be invoked are probably not reducible to any general formulation of principle,” Allen [v. Zurich Ins. | 1 | 2006–2006 |
Middlebrook Tech, LLC v. Moore
green
2 sentences2006“The clean hands doctrine is not applied for the protection of the parties nor as a punishment to the wrongdoer; rather, the doctrine is intended to protect the courts from having to endorse or reward inequitable conduct.” [Quoting Adams v. Manown, 328 Md. 463, 474-75 , 615 A.2d 611 (1992).] We noted in Middlebrook Tech, LLC v. Moore, 157 Md.App. 40, 62-63 , 849 A.2d 63 (2004), and also in Gordon v. Posner, 142 Md.App. 399, 426-27 , 790 A.2d 675 , cert. denied, 369 Md. 180 , 798 A.2d 552 (2002), that courts have typically focused upon three factors in making the determination of whether a part 2006“The clean hands doctrine is not applied for the protection of the parties nor as a punishment to the wrongdoer; rather, the doctrine is intended to protect the courts from having to endorse or reward inequitable conduct.” [Quoting Adams v. Manown, 328 Md. 463, 474-75 , 615 A.2d 611 (1992).] We noted in Middlebrook Tech, LLC v. Moore, 157 Md.App. 40, 62-63 , 849 A.2d 63 (2004), and also in Gordon v. Posner, 142 Md.App. 399, 426-27 , 790 A.2d 675 , cert. denied, 369 Md. 180 , 798 A.2d 552 (2002), that courts have typically focused upon three factors in making the determination of whether a part | 1 | 2006–2006 |
Townsend v. Morgan
green
2 sentences1994This Court would not apply a clean hands defense to a complaint for annulment in Townsend v. Morgan, 192 Md. 168 , 63 A.2d 743 (1949). . 1994This Court would not apply a clean hands defense to a complaint for annulment in Townsend v. Morgan, 192 Md. 168 , 63 A.2d 743 (1949). [5] A subcontractor also joined as a claimant, but that is immaterial for present purposes. | 1 | 1994–1994 |
Messick v. Smith
green
2 sentences1992The court concluded that the clean hands doctrine applies at law, relying on Messick v. Smith, 193 Md. 659 , 69 A.2d 478 (1949) and Shirks Motor Express Corp. v. Forster Transfer & Rigging Co., 214 Md. 18 , 133 A.2d 59 (1957). 1992The court concluded that the clean hands doctrine applies at law, relying on Messick v. Smith, 193 Md. 659 , 69 A.2d 478 (1949) and Shirks Motor Express Corp. v. Forster Transfer & Rigging Co., 214 Md. 18 , 133 A.2d 59 (1957). | 1 | 1992–1992 |
Shirks Motor Express Corp. v. Forster Transfer & Rigging Co.
green
2 sentences1992The court concluded that the clean hands doctrine applies at law, relying on Messick v. Smith, 193 Md. 659 , 69 A.2d 478 (1949) and Shirks Motor Express Corp. v. Forster Transfer & Rigging Co., 214 Md. 18 , 133 A.2d 59 (1957). 1992The court concluded that the clean hands doctrine applies at law, relying on Messick v. Smith, 193 Md. 659 , 69 A.2d 478 (1949) and Shirks Motor Express Corp. v. Forster Transfer & Rigging Co., 214 Md. 18 , 133 A.2d 59 (1957). | 1 | 1992–1992 |
Mas v. Coca-Cola Co.
green
2 sentences1958Mas v. Coca-Cola Co., 163 F.2d 505 . 1958Mas v. Coca-Cola Co., 163 F. 2d 505 . | 1 | 1958–1958 |
Berman v. Berman
green
2 sentences1952This Court has repeatedly held (and now holds) that divorces should not be granted for light or trivial causes; but few opinions in divorce cases indicate that the conduct of either of the parties has been exemplary." Assuming without deciding that the clean hands doctrine applies here, Berman v. Berman, 191 Md. 699, 704 , 62 A.2d 787 , if the wife had removed property from a house other than that of her husband, without authority, she would have been guilty of "doing an act not authorized in law". 1952This Court has repeatedly held (and now holds) that divorces should not be granted for light or trivial causes; but few opinions in divorce cases indicate that the conduct of either of the parties has been exemplary." Assuming without deciding that the clean hands doctrine applies here, Berman v. Berman, 191 Md. 699, 704 , 62 A.2d 787 , if the wife had removed property from a house other than that of her husband, without authority, she would have been guilty of "doing an act not authorized in law". | 1 | 1952–1952 |
Meeks v. Meeks
neutral
2 sentences1952This Court said, 189 Md. at page 87 , 54 A.2d at page 337 : "The defense of recrimination can be sustained only by proof of a marital offense which would constitute grounds for divorce. 1952This Court said, 189 Md. at page 87 , 54 A.2d at page 337 : "The defense of recrimination can be sustained only by proof of a marital offense which would constitute grounds for divorce. | 1 | 1952–1952 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.