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23 Maryland opinions name it 2 courts 1968–2017 0 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 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). | 7 | 12 |
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). | 2 | 4 |
Simard v. Bursongreen2 sentences2015See Simard v. Burson, 197 Md.App. 396, 416-17, n. 11 , 14 A.3d 6 (2011); aff'd, 424 Md. 318, 332 , 35 A.3d 1154 (2012). 2015See Simard v. Burson, 197 Md.App. 396, 416-17, n. 11 , 14 A.3d 6 (2011); aff'd, 424 Md. 318, 332 , 35 A.3d 1154 (2012). | 2 | 2 |
Hicks v. Gilbertgreen2 sentences2010We explained this equitable doctrine in Wells Fargo v. Neal: The [unjclean 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 [v. Altevogt], 239 Md. [43,] 48, 210 A.2d [153,] 156 [ (1965) ]; see also Hicks v. Gilbert, 135 Md.App. 394, 400 , 762 A.2d 986, 989-90 (2000). 2010We explained this equitable doctrine in Wells Fargo v. Neal: The [unjclean 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 [v. Altevogt], 239 Md. [43,] 48, 210 A.2d [153,] 156 [ (1965) ]; see also Hicks v. Gilbert, 135 Md.App. 394, 400 , 762 A.2d 986, 989-90 (2000). | 2 | 2 |
Turner v. Turnergreen2 sentences2014App. 350 , 809 A.2d 18 (2002), a case in which the intermediate appellate court affirmed the application of the unclean hands doctrine in a divorce proceeding, is inapposite. 31 Our holding, of course, has no impact on the County’s right to pursue fines or other recourse because of Wagner’s construction activities. 40 Minimum Variance Necessary Petitioners’ best argument is that the variance sought is not the minimum necessary to afford Wagner relief. 2014App. 350 , 809 A.2d 18 (2002), a case in which the intermediate appellate court affirmed the application of the unclean hands doctrine in a divorce proceeding, is inapposite. 31 Our holding, of course, has no impact on the County’s right to pursue fines or other recourse because of Wagner’s construction activities. 40 Minimum Variance Necessary Petitioners’ best argument is that the variance sought is not the minimum necessary to afford Wagner relief. | 1 | 5 |
Wells Fargo Home Mortgage, Inc. v. Nealgreen2 sentences2015Citing Wells Fargo Home Mortgage, Inc. v. Neal, 398 Md. 705, 729-30 , 922 A.2d 538 (2007), the court said that the unclean hands doctrine provides 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.” The judge did not explicitly find that Greentree’s conduct was “fraudulent, illegal, or inequitable,” but, implied that this was the case. 2015Citing Wells Fargo Home Mortgage, Inc. v. Neal, 398 Md. 705, 729-30 , 922 A.2d 538 (2007), the court said that the unclean hands doctrine provides 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.” The judge did not explicitly find that Greentree’s conduct was “fraudulent, illegal, or inequitable,” but, implied that this was the case. | 1 | 3 |
Schneider v. Schneidergreen2 sentences2000See Schneider v. Schneider, 96 Md.App. 296, 312 , 624 A.2d 1319 (1993), rev'd on other grounds, 335 Md. 500 , 644 A.2d 510 (1994). 2000See Schneider v. Schneider, 96 Md.App. 296, 312 , 624 A.2d 1319 (1993), rev'd on other grounds, 335 Md. 500 , 644 A.2d 510 (1994). | 1 | 2 |
Mona v. Mona Electric Group, Inc.green2 sentences2017Grp., Inc., 176 Md.App. 672, 710 , 934 A.2d 450, 472 (2007), in which the Court of Special Appeals affirmed a trial court’s sua sponte raising the doctrine of unclean hands at a JNOV hearing and entering JNOV, in part, on that basis. 2017Grp., Inc., 176 Md.App. 672, 710 , 934 A.2d 450, 472 (2007), in which the Court of Special Appeals affirmed a trial court’s sua sponte raising the doctrine of unclean hands at a JNOV hearing and entering JNOV, in part, on that basis. | 1 | 1 |
Dickerson v. Longoriagreen2 sentences2017The doctrine does not mandate that those seeking equitable relief must have exhibited unblemished conduct in every transaction to which they have ever been a party, but rather that the particular matter for which a litigant seeks equitable relief must not be marred by any fraudulent, illegal, or inequitable conduct. *126 Dickerson v. Longoria, 414 Md. 419, 455 , 995 A.2d 721, 743 (2010) (citation, brackets, and internal quotation marks omitted). 2017The doctrine does not mandate that those seeking equitable relief must have exhibited unblemished conduct in every transaction to which they have ever been a party, but rather that the particular matter for which a litigant seeks equitable relief must not be marred by any fraudulent, illegal, or inequitable conduct. *126 Dickerson v. Longoria, 414 Md. 419, 455 , 995 A.2d 721, 743 (2010) (citation, brackets, and internal quotation marks omitted). | 1 | 1 |
Tower Oaks Boulevard, LLC v. Procidagreen2 sentences2017The trial court “then went on to address the merits of the motion to stay and dismiss, opining that if the motion to stay and dismiss had been authorized, the wrongful conduct [of another entity] ... would not eliminate [that entity’s] right to foreclose, as a matter of law or under the unclean hands doctrine.” Id. at 392 , 100 A.3d at 1265 (emphasis omitted). 2017The trial court “then went on to address the merits of the motion to stay and dismiss, opining that if the motion to stay and dismiss had been authorized, the wrongful conduct [of another entity] ... would not eliminate [that entity’s] right to foreclose, as a matter of law or under the unclean hands doctrine.” Id. at 392 , 100 A.3d at 1265 (emphasis omitted). | 1 | 1 |
Schneider v. Schneidergreen2 sentences2000See Schneider v. Schneider, 96 Md.App. 296, 312 , 624 A.2d 1319 (1993), rev'd on other grounds, 335 Md. 500 , 644 A.2d 510 (1994). 2000See Schneider v. Schneider, 96 Md.App. 296, 312 , 624 A.2d 1319 (1993), rev'd on other grounds, 335 Md. 500 , 644 A.2d 510 (1994). | 1 | 1 |
McClees v. McCleesgreen2 sentences1993See, e.g., McClees v. McClees, 162 Md. 70, 80-81 , 158 A. 349 (1932); Childs v. Childs, 49 Md. 509, 513 (1878). 4 . 1993See, e.g., McClees v. McClees, 162 Md. 70, 80-81 , 158 A. 349 (1932); Childs v. Childs, 49 Md. 509, 513 (1878). 4 . | 1 | 1 |
Childs v. Childsgreen1 sentence1993See, e.g., McClees v. McClees, 162 Md. 70, 80-81 , 158 A. 349 (1932); Childs v. Childs, 49 Md. 509, 513 (1878). 4 . | 1 | 1 |
Messick v. Smithgreen2 sentences1991See Messick, 193 Md. at 667-671 , 69 A.2d 478 (using “in pari delicto" and "clean hands” interchangeably). 1991See Messick, 193 Md. at 667-671 , 69 A.2d 478 (using “in pari delicto" and "clean hands” interchangeably). | 1 | 1 |
Castiglione v. Johns Hopkins Hospitalgreen2 sentences1991See Castiglione v. Johns Hopkins Hospital, 69 Md.App. 325, 333 , 517 A.2d 786 (1986), quoting Vanhook v. Merchants Mutual Ins. 1991See Castiglione v. Johns Hopkins Hospital, 69 Md.App. 325, 333 , 517 A.2d 786 (1986), quoting Vanhook v. Merchants Mutual Ins. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
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 | 2002–2007 |
Simard v. White
green
1 sentence2015The court emphasized that, due to Greentree’s default, “more than a 2 In support of that statement, the circuit court quoted from Simard v. White, 383 Md. at 320 -21 as follows: [T]he Court, then, has remained cognizant of the need to protect the interests of the mortgagor, who has not been relieved of his liability for deficiency on the mortgage at any time during the sale and resale in the foreclosure process, as well as the interest of the mortgagee who has invoked the power of the court in pursuit of satisfaction of the debt owed to him. 7 year had passed since the first sale was ratified | 1 | 2015–2015 |
Roper v. Camuso
green
1 sentence2015Id. at 273-74, 829 A.2d 589 . 9 . | 1 | 2015–2015 |
Burson v. Simard
green
2 sentences2015See Simard v. Burson, 197 Md.App. 396, 416-17, n. 11 , 14 A.3d 6 (2011); aff'd, 424 Md. 318, 332 , 35 A.3d 1154 (2012). 2015See Simard v. Burson, 197 Md.App. 396, 416-17, n. 11 , 14 A.3d 6 (2011); aff'd, 424 Md. 318, 332 , 35 A.3d 1154 (2012). | 1 | 2015–2015 |
Sherwood Co. v. Sherwood Distilling Co.
green
2 sentences2000Citing Sherwood Company v. Sherwood Distilling Company, 177 Md. 455 , 9 A.2d 842 (1939), he urged the unclean hands doctrine did not apply because he paid his creditors. 2000Citing Sherwood Company v. Sherwood Distilling Company, 177 Md. 455 , 9 A.2d 842 (1939), he urged the unclean hands doctrine did not apply because he paid his creditors. | 1 | 2000–2000 |
Bland v. Larsen
green
2 sentences1994In Bland v. Larsen, 97 Md.App. 125 , 627 A.2d 79 (1993), Bland asserted on appeal that the trial court had erred in failing to apply the doctrine of unclean hands. 1994In Bland v. Larsen, 97 Md.App. 125 , 627 A.2d 79 (1993), Bland asserted on appeal that the trial court had erred in failing to apply the doctrine of unclean hands. | 1 | 1994–1994 |
Truitt v. Miller
green
2 sentences1992For example, the District of Columbia Court of Appeals in Truitt v. Miller, 407 A.2d 1073 (D.C. 1979), held: "Although `unclean hands' is a companion principle to the doctrine of in pari delicto, Tarasi v. Pittsburgh National Bank, 555 F.2d 1152 , 1156-57 n. 9 (3d Cir.1977), it has no applicability in an action for damages." Id. at 1079-80; see also Ligon v. E.F. 1992For example, the District of Columbia Court of Appeals in Truitt v. Miller, 407 A.2d 1073 (D.C.1979), held: “Although ‘unclean hands’ is a companion principle to the doctrine of in pari delicto, Tarasi v. Pittsburgh National Bank, 555 F.2d 1152 , 1156-57 n. 9 (3d Cir.1977), it has no applicability in an action for damages.” Id. at 1079-80; see also Ligon v. E.F. | 1 | 1992–1992 |
William TARASI, George Sampas and Virginia R. Harrigan, Appellants, v. PITTSBURGH NATIONAL BANK and S. Robert Mialki
green
2 sentences1992For example, the District of Columbia Court of Appeals in Truitt v. Miller, 407 A.2d 1073 (D.C. 1979), held: "Although `unclean hands' is a companion principle to the doctrine of in pari delicto, Tarasi v. Pittsburgh National Bank, 555 F.2d 1152 , 1156-57 n. 9 (3d Cir.1977), it has no applicability in an action for damages." Id. at 1079-80; see also Ligon v. E.F. 1992For example, the District of Columbia Court of Appeals in Truitt v. Miller, 407 A.2d 1073 (D.C.1979), held: “Although ‘unclean hands’ is a companion principle to the doctrine of in pari delicto, Tarasi v. Pittsburgh National Bank, 555 F.2d 1152 , 1156-57 n. 9 (3d Cir.1977), it has no applicability in an action for damages.” Id. at 1079-80; see also Ligon v. E.F. | 1 | 1992–1992 |
Niner v. Hanson
green
2 sentences1991Miner, 217 Md. at 309 , 142 A.2d 798 . 1991Miner, 217 Md. at 309 , 142 A.2d 798 . | 1 | 1991–1991 |
Hlista v. Altevogt
green
2 sentences1991Hlista v. Altevogt, 239 Md. 43, 48 , 210 A.2d 153 (1965). 1991Hlista v. Altevogt, 239 Md. 43, 48 , 210 A.2d 153 (1965). | 1 | 1991–1991 |
Space Aero Products Co. v. R. E. Darling Co.
green
1 sentence1968Darling Co., supra, 238 Md. at 120 , and is seldom a defense available in an unfair competition action. | 1 | 1968–1968 |
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.