23 Ohio opinions name it 2 courts 1998–2026 12 in the last five years
The cases below were cited by Ohio 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 |
|---|---|---|
Patterson v. Blantongreen2 sentences1998See, also, Patterson v. Blanton (1996), 109 Ohio App.3d 349, 354 , 672 N.E.2d 208, 211 (discussing the doctrine of unclean hands). 1998See, also, Patterson v. Blanton (1996), 109 Ohio App.3d 349, 354 , 672 N.E.2d 208, 211 (discussing the doctrine of unclean hands). | 2 | 2 |
Basil v. Vincellogreen2 sentences2026DeWine v. Shadyside Party Ctr., 2014-Ohio-2357, ¶ 29 (7th Dist.), citing Basil v. Vincello, 50 Ohio St.3d 185 (1990). 2026Basil v. Vincello, 50 Ohio St. 3d 185, 190 (1990). | 1 | 2 |
North Coast Cookies, Inc. v. Sweet Temptations, Inc.green1 sentence2026A party’s conduct in the litigation itself may cause it to suffer sanctions, but it will not invoke the ‘clean hands’ doctrine.” N. Coast Cookies, Inc. v. Sweet Temptations, Inc., 16 Ohio App.3d 342, 344, fn. 1 (8th Dist. 1984). | 1 | 1 |
State ex rel. DeWine v. Shadyside Party Ctr.green1 sentence2026DeWine v. Shadyside Party Ctr., 2014-Ohio-2357, ¶ 29 (7th Dist.), citing Basil v. Vincello, 50 Ohio St.3d 185 (1990). | 1 | 1 |
State ex rel. Miller v. Hamilton Cty. Bd. of Elections (Slip Opinion)green1 sentence2025Bd. of Elections, 2021-Ohio-831, ¶ 16 (noting in a prohibition action that we have occasionally 14 January Term, 2025 recognized the “potential applicability” of the unclean-hands defense in mandamus actions). | 1 | 1 |
Pons v. Ohio State Medical Boardgreen1 sentence2025Bd., 66 Ohio St.3d 619, 621 (1993). {¶27} Turning first to Copley Tire’s second assignment of error, it argues that its objection “refers to specific findings by the magistrate.” In support, Copley Tire points to the memorandum in support of its objection wherein it alleges that “the [m]agistrate erred and abused his discretion in granting [Proamerica] judgment for back rent after the lockout.” It further states that its memorandum in support “analyzes the doctrine of unclean hands, which indicates the basis upon which the objection was filed[,] [and] [t]hus, it satisfies the requirement of Ci | 1 | 1 |
Littler v. Janisgreen1 sentence2025We initially observe that the doctrine of 18 Case No. 2024-P-0046 unclean hands “is an affirmative defense,” and generally must “be raised in the pleadings or in an amendment to the pleading, or it is waived.” (Citations omitted.) Littler v. Janis, 2024-Ohio-1145, ¶ 29 (10th Dist.). | 1 | 1 |
Goldberger v. Bexley Propertiesgreen1 sentence2023However, the unclean hands doctrine “ ‘requires only that the plaintiff must not be guilty of reprehensible conduct with respect to the subject-matter of his suit.’ ” Goldberger v. Bexley Properties, 5 Ohio St.3d 82, 85 (1983), quoting Kinner v. Lake Shore & Michigan S. Ry. | 1 | 1 |
HSBC Bank USA, Natl. Assn. v. Banksgreen1 sentence2022Cuyahoga No. 111241, 2022-Ohio-3044, ¶ 22 (“Appellant did not file an answer and assert [the doctrine of unclean hands] at the trial-court level. | 1 | 1 |
Graham v. City of Lakewoodgreen2 sentences2021“For a trial court to grant a motion to dismiss for failure to state a claim upon which relief can be granted, it must appear ‘beyond doubt from the complaint that the plaintiff can prove no set of facts entitling her [or him] to relief.’” Graham v. Lakewood, 2018-Ohio-1850 , 113 N.E.3d 44, ¶ 47 (8th Dist.), quoting Grey v. Walgreen Co., 197 Ohio App.3d 418 , 2018-Ohio-6167 , 967 N.E.2d 1249, ¶ 3 (8th Dist.). {¶ 48} Under the doctrine of unclean hands, “one who seeks equity must do equity.” State ex rel. 2021“For a trial court to grant a motion to dismiss for failure to state a claim upon which relief can be granted, it must appear ‘beyond doubt from the complaint that the plaintiff can prove no set of facts entitling her [or him] to relief.’” Graham v. Lakewood, 2018-Ohio-1850 , 113 N.E.3d 44, ¶ 47 (8th Dist.), quoting Grey v. Walgreen Co., 197 Ohio App.3d 418 , 2018-Ohio-6167 , 967 N.E.2d 1249, ¶ 3 (8th Dist.). {¶ 48} Under the doctrine of unclean hands, “one who seeks equity must do equity.” State ex rel. | 1 | 1 |
Grey v. Walgreen Co.green2 sentences2021“For a trial court to grant a motion to dismiss for failure to state a claim upon which relief can be granted, it must appear ‘beyond doubt from the complaint that the plaintiff can prove no set of facts entitling her [or him] to relief.’” Graham v. Lakewood, 2018-Ohio-1850 , 113 N.E.3d 44, ¶ 47 (8th Dist.), quoting Grey v. Walgreen Co., 197 Ohio App.3d 418 , 2018-Ohio-6167 , 967 N.E.2d 1249, ¶ 3 (8th Dist.). {¶ 48} Under the doctrine of unclean hands, “one who seeks equity must do equity.” State ex rel. 2021“For a trial court to grant a motion to dismiss for failure to state a claim upon which relief can be granted, it must appear ‘beyond doubt from the complaint that the plaintiff can prove no set of facts entitling her [or him] to relief.’” Graham v. Lakewood, 2018-Ohio-1850 , 113 N.E.3d 44, ¶ 47 (8th Dist.), quoting Grey v. Walgreen Co., 197 Ohio App.3d 418 , 2018-Ohio-6167 , 967 N.E.2d 1249, ¶ 3 (8th Dist.). {¶ 48} Under the doctrine of unclean hands, “one who seeks equity must do equity.” State ex rel. | 1 | 1 |
Schaaf v. Schaaf, Unpublished Decision (6-14-2006)green1 sentence2016Medina No. 05CA0060-M, 2006-Ohio-2983, ¶ 34 (“[T]his Court is hard pressed to see how, outside of his poor credit and indebtedness due largely to his own failure to pay support payments, [former husband] is in such dire financial straits to warrant termination of his support obligation.”) {¶25} Even if we assume for argument’s sake that the trial court misapplied the doctrine of unclean hands, the error was harmless. | 1 | 1 |
Jones v. Hyatt Legal Services (In Re Dow)green1 sentence2015The doctrine of unclean hands “precludes one who has defrauded his adversary in the subject matter of the action from equitable relief.” In re Dow, 132 B.R. 853, 860 (Bankr.S.D.Ohio 1991) (the doctrine of unclean hands does not apply where there is no allegation that the plaintiffs defrauded the defendant). 2. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Miller v. Miller
green
2 sentences2010Furthermore, “the unclean hands doctrine should not be imposed where a party has legal remedies available to address an opposing party’s asserted misconduct.” Safranek v. Safranek, Cuyahoga App. No. 80413, 2002-Ohio-5066 , 2002 WL 31123864 , at ¶ 20, citing Miller v. Miller (1993), 92 Ohio App.3d 340, 348-349 , 635 N.E.2d 384 . {¶ 25} Deutsche argues that the doctrine of unclean hands should not apply because “[t]he Pevarskis do not allege any reprehensible conduct by Deutsche, the current holder of the Note. * * * Rather, the Pevarskis rely on alleged conduct by Ameriquest, the lender.” In re 2010Furthermore, “the unclean hands doctrine should not be imposed where a party has legal remedies available to address an opposing party’s asserted misconduct.” Safranek v. Safranek, Cuyahoga App. No. 80413, 2002-Ohio-5066 , 2002 WL 31123864 , at ¶ 20, citing Miller v. Miller (1993), 92 Ohio App.3d 340, 348-349 , 635 N.E.2d 384 . {¶ 25} Deutsche argues that the doctrine of unclean hands should not apply because “[t]he Pevarskis do not allege any reprehensible conduct by Deutsche, the current holder of the Note. * * * Rather, the Pevarskis rely on alleged conduct by Ameriquest, the lender.” In re | 4 | 2007–2011 |
Wiley v. Wiley, 9-06-34 (12-3-2007)
neutral
2 sentences2011“Thus, for the doctrine of unclean hands to apply, the offending conduct must constitute reprehensible, grossly inequitable, or unconscionable conduct, rather than mere negligence, ignorance, or inappropriateness.” Wiley v. Wiley, Marion App. No. 9-06-34, 2007-Ohio-6423, ¶ 15 . 2010A. Unclean Hands {¶ 23} Under their sole assignment of error, the Pevarskis argue that genuine issues of material fact exist regarding the equitable defense of unclean hands. {¶ 24} “[I]t is fundamental that he who seeks equity must do equity, and that he must come into court with clean hands.” Christman v. Christman (1960), 171 Ohio St. 152 , 154, 12 O.O.2d 172 , 168 N.E.2d 153 . “[F]or the doctrine of unclean hands to apply, the offending conduct must constitute reprehensible, grossly inequitable, or unconscionable conduct, rather than mere negligence, ignorance, or inappropriateness.” Wiley | 3 | 2008–2011 |
Key Bank Natl. Assoc. v. Bolin
neutral
2 sentences2024Id. {¶18} Appellant next argues appellee misled her and thus appellee’s claims are barred by the doctrine of unclean hands. 2013Moreover, nowhere in Jackson’s affidavit does he state that GMAC ever affirmatively stated that Jackson would qualify for loan modification. {¶33} The Fifth District considered a similar argument in Key Bank Nat’l Assoc. v. Bolin, No. 2010CA00285, 2011-Ohio-4532 , wherein Bolin argued that the bank was estopped from seeking equitable relief because of the doctrine of unclean hands, on the basis that the bank would not allow Bolin to participate in a loan modification program. | 2 | 2013–2024 |
Sharp v. Miller
green
1 sentence2024No. 17 JE 0022, 2018-Ohio-4740, ¶ 37 . {¶ 30} Based on the record presented, we find unpersuasive any contention the trial court abused its discretion in failing to apply the doctrine of unclean hands. | 1 | 2024–2024 |
Crawford v. Hawes
green
2 sentences2021Accordingly, the unclean hands doctrine or law precluding enforcement of claims based on illegal acts did not justify the Complaint’s dismissal. {¶ 25} Furthermore, in Crawford v. Hawes, 2013-Ohio-3173 , 995 N.E.2d 966 (2d -12- Dist.), a co-partner was allowed to recover on unjust enrichment claims even though the trial court found that the parties had entered into an illegal contract. 2021Accordingly, the unclean hands doctrine or law precluding enforcement of claims based on illegal acts did not justify the Complaint’s dismissal. {¶ 25} Furthermore, in Crawford v. Hawes, 2013-Ohio-3173 , 995 N.E.2d 966 (2d -12- Dist.), a co-partner was allowed to recover on unjust enrichment claims even though the trial court found that the parties had entered into an illegal contract. | 1 | 2021–2021 |
Marinaro v. Major Indoor Soccer League
green
2 sentences2016Marinaro v. Major Indoor Soccer League, 81 Ohio App.3d 42 , 610 N.E.2d 450 (1991). 2016Marinaro v. Major Indoor Soccer League, 81 Ohio App.3d 42 , 610 N.E.2d 450 (1991). | 1 | 2016–2016 |
Rivers v. Otis Elevator
green
1 sentence2015Rivers v. Otis Elevator, 2013-Ohio-3917 , 996 N.E.2d 1039 , ¶ 35 (8th Dist.). | 1 | 2015–2015 |
Dorsey v. Contemporary Obstetrics & Gynecology, Inc.
green
2 sentences2010Dorsey v. Contemporary Obstetrics & Gynecology, Inc. (1996), 113 Ohio App.3d 75, 80 , 680 N.E.2d 240 . “ ‘Unconscionability has generally been recognized to include an absence of meaningful choice on the part of one of the parties together with contract terms which are unreasonably favorable to the other party. 2010Dorsey v. Contemporary Obstetrics & Gynecology, Inc. (1996), 113 Ohio App.3d 75, 80 , 680 N.E.2d 240 . “ ‘Unconscionability has generally been recognized to include an absence of meaningful choice on the part of one of the parties together with contract terms which are unreasonably favorable to the other party. | 1 | 2010–2010 |
Smiddy v. Wedding Party, Inc.
green
1 sentence2004Smiddy v. The Wedding Party, Inc. (1987), 30 Ohio St.3d 35 , 36 . | 1 | 2004–2004 |
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.