unclean hands doctrine (Virginia) · Go Syfert
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unclean hands doctrine in Virginia

11 Virginia opinions name it 3 courts 1998–2026 4 in the last five years

The cases below were cited by Virginia 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 (7)

CaseFollowedCited
Richards v. Musselmangreen
va · 1980 · cited in 4 Virginia opinions naming this issue, 2006–2025
2 sentences

2025The equitable doctrine of unclean hands “does not demand that its suitors shall have led blameless lives.” Richards v. Musselman, 221 Va. 181, 186 (1980) (quoting Loughran v. Loughran, 292 U.S. 216, 229 (1934)).

2022The circuit court in this case focused on the unclean hands doctrine, “an ancient maxim of equity courts,” Richards v. Musselman, 221 Va. 181, 185 (1980), deeply embedded in the history of Anglo-American chancery courts.

24
Walker v. Hendersongreen
vactapp · 1928 · cited in 2 Virginia opinions naming this issue, 2002–2002
2 sentences

2002Assuming, without deciding, that the unclean hands doctrine applies to these circumstances, we do not conclude that mother lacked “clean hands.” “[H]e who asks equity must do equity, and he who comes into equity must come with clean hands.” Walker v. Henderson, 151 Va. 913, 927-28 , 145 S.E. 311, 315 (1928).

2002Assuming, without deciding, that the unclean hands doctrine applies to these circumstances, we do not conclude that mother lacked “clean hands.” “[H]e who asks equity must do equity, and he who comes into equity must come with clean hands.” Walker v. Henderson, 151 Va. 913, 927-28 , 145 S.E. 311, 315 (1928).

22
Wiglesworth v. Taylorgreen
va · 1990 · cited in 2 Virginia opinions naming this issue, 2011–2026
2 sentences

2026But as Dorothy correctly points out, it was the plaintiff in Wiglesworth who asserted the unclean hands doctrine to defeat the defendant’s laches defense. 239 Va. at 608-09 .

2011Wiglesworth v. Taylor, 239 Va. 603, 608 , 391 S.E.2d 299, 303 (1990). -3- Based upon a review of the circumstances in this case, we cannot say that the trial judge abused his discretion in applying the doctrine of unclean hands.

12
Loughran v. Loughrangreen
scotus · 1934 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025The equitable doctrine of unclean hands “does not demand that its suitors shall have led blameless lives.” Richards v. Musselman, 221 Va. 181, 186 (1980) (quoting Loughran v. Loughran, 292 U.S. 216, 229 (1934)).

11
Maldonado v. Ford Motor Co.green
mich · 2006 · cited in 1 Virginia opinions naming this issue, 2024–2024
1 sentence

2024See, e.g., Maldonado v. Ford Motor Co., 719 N.W.2d 809, 818 (Mich. 2006) (affirming dismissal of damages claim because of litigant’s unclean hands, finding “despite its origins, [the clean hands doctrine] is applicable to both equitable and legal damage claims”); Fremont Homes, Inc. v. Elmer, 974 P.2d 952 (Wyo. 1999) (determining the unclean hands doctrine does not apply to legal remedies).

11
Westbrook v. Westbrookgreen
vactapp · 1988 · cited in 1 Virginia opinions naming this issue, 2015–2015
2 sentences

2015We have held, however, that “[t]he ‘clean hands doctrine’ is unavailable to a party when it is asserted in *458 the context of equitable distribution proceedings,” Westbrook v. Westbrook, 5 Va.App. 446, 457 , 364 S.E.2d 523, 530 (1988), and that it “does not apply to the determination of a spousal support award pursuant to Code § 20-107.1,” Huger v. Huger, 16 Va.App. 785, 791 , 433 S.E.2d 255, 259 (1993).

2015We have held, however, that “[t]he ‘clean hands doctrine’ is unavailable to a party when it is asserted in *458 the context of equitable distribution proceedings,” Westbrook v. Westbrook, 5 Va.App. 446, 457 , 364 S.E.2d 523, 530 (1988), and that it “does not apply to the determination of a spousal support award pursuant to Code § 20-107.1,” Huger v. Huger, 16 Va.App. 785, 791 , 433 S.E.2d 255, 259 (1993).

11
Huger v. Hugergreen
vactapp · 1993 · cited in 1 Virginia opinions naming this issue, 2015–2015
2 sentences

2015We have held, however, that “[t]he ‘clean hands doctrine’ is unavailable to a party when it is asserted in *458 the context of equitable distribution proceedings,” Westbrook v. Westbrook, 5 Va.App. 446, 457 , 364 S.E.2d 523, 530 (1988), and that it “does not apply to the determination of a spousal support award pursuant to Code § 20-107.1,” Huger v. Huger, 16 Va.App. 785, 791 , 433 S.E.2d 255, 259 (1993).

2015We have held, however, that “[t]he ‘clean hands doctrine’ is unavailable to a party when it is asserted in *458 the context of equitable distribution proceedings,” Westbrook v. Westbrook, 5 Va.App. 446, 457 , 364 S.E.2d 523, 530 (1988), and that it “does not apply to the determination of a spousal support award pursuant to Code § 20-107.1,” Huger v. Huger, 16 Va.App. 785, 791 , 433 S.E.2d 255, 259 (1993).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Fremont Homes, Inc. v. Elmer green
wyo · 1999
1 sentence

2024See, e.g., Maldonado v. Ford Motor Co., 719 N.W.2d 809, 818 (Mich. 2006) (affirming dismissal of damages claim because of litigant’s unclean hands, finding “despite its origins, [the clean hands doctrine] is applicable to both equitable and legal damage claims”); Fremont Homes, Inc. v. Elmer, 974 P.2d 952 (Wyo. 1999) (determining the unclean hands doctrine does not apply to legal remedies).

12024–2024
Butler v. Hayes green
va · 1997
2 sentences

1998In Butler v. Hayes, 254 Va. 38 , 487 S.E.2d 229 (1997), the Virginia Supreme Court applied the equitable doctrine of “unclean hands.” In Butler , the defendant purchased a parcel of property.

1998In Butler v. Hayes, 254 Va. 38 , 487 S.E.2d 229 (1997), the Virginia Supreme Court applied the equitable doctrine of “unclean hands.” In Butler , the defendant purchased a parcel of property.

11998–1998

Statutes the citing opinions construe

VA § Va. Code Ann. § 17.1-413 (4) VA § Va. Code Ann. § 20-108.1 (3)

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.

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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