clean hands doctrine in Louisiana

10 Louisiana opinions name it 1 courts 2014–2023 2 in the last five years

The cases below were cited by Louisiana 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 (5)

Case	Followed	Cited
City of New Orleans v. Levygreen la · 1957 · cited in 3 Louisiana opinions naming this issue, 2017–2023 2 sentences 2023The equitable doctrine of clean hands, sometimes referred to as " unclean hands," mandates that "[ h] e who comes into a court of equity must come with clean hands." Cimarex Energy Co. v. Mauboules, 2009- 1170 ( La. 419110), 40 So. 3d 931 , 945 quoting City of New Orleans v. Levy, 233 La. 844, 865 , 98 So.2d 210, 218 ( 1957)). 2023The equitable doctrine of clean hands, sometimes referred to as " unclean hands," mandates that "[ h] e who comes into a court of equity must come with clean hands." Cimarex Energy Co. v. Mauboules, 2009- 1170 ( La. 419110), 40 So. 3d 931 , 945 quoting City of New Orleans v. Levy, 233 La. 844, 865 , 98 So.2d 210, 218 ( 1957)).	2	3
Cimarex Energy Co. v. Mauboulesgreen la · 2010 · cited in 3 Louisiana opinions naming this issue, 2017–2023 2 sentences 2023The equitable doctrine of clean hands, sometimes referred to as " unclean hands," mandates that "[ h] e who comes into a court of equity must come with clean hands." Cimarex Energy Co. v. Mauboules, 2009- 1170 ( La. 419110), 40 So. 3d 931 , 945 quoting City of New Orleans v. Levy, 233 La. 844, 865 , 98 So.2d 210, 218 ( 1957)). 2022The court recognized that a “party who seeks equitable relief, must not be pari delicto; that is, he himself must be free from any unlawful or inequitable conduct with respect to the matter or transaction in question.” Id. [Emphasis added.] More recently, in Cimarex Energy Co. v. Mauboules, 09-1170, 09-1180, 09- 1194 (La. 4/9/10), 40 So.3d 931, 945 , the Supreme Court quoted the language cited above from City of New Orleans v. Levy, supra, regarding the equitable nature of the unclean hands doctrine and declined to find that the plaintiff violated the clean hands doctrine, or otherwise acted i	1	3
Bank of Sunset & Trust Co. v. Charlotgreen lactapp · 1993 · cited in 1 Louisiana opinions naming this issue, 2022–2022 1 sentence 2022Louisiana courts recognize that the “purpose of the concursus proceeding is equitable in nature, meaning to protect a person finding himself in possession of money which is not his from having to referee the rights of rival claimants and risk paying same to the wrong party.” Bank of Sunset & Trust Co. v. Charlot, 614 So.2d 1386, 1388 (La.	1	1
Bossier Parish School Board v. Pioneer Credit Recovery, Inc.green lactapp · 2015 · cited in 1 Louisiana opinions naming this issue, 2022–2022 1 sentence 2022C.C. art. 4, courts may resort to equity only when “no rule for a particular situation can be derived from legislation or custom.” Id; see also Bossier, 161 So.3d at 1009 (finding the unclean hands doctrine did not apply because the existence of positive law on the subject precluded the application of equitable concepts).	1	1
Holloway Drilling Equipment, Inc. v. Bodingreen lactapp · 2012 · cited in 1 Louisiana opinions naming this issue, 2015–2015 1 sentence 2015To find otherwise would “condone criminal activity” and such a result would “run[ ] afoul with public policy considerations, the State’s clean hands doctrine, and the statutory and jurisprudential precedent!.]” Holloway Drilling I, 107 So.3d at 712 (Saunders, J., dissenting).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Louisiana. Read the followed side critically anyway.

Also cited on this issue (16)

Case	Cited	Years
Guilbeau v. Domingues green lactapp · 2014 2 sentences 2022App. 3 Cir. 10/1/14), 149 So.3d 825, 829 , writ denied, 14-2283 (La. 1/16/15), 157 So.3d 1132 , for its statement that “the clean hands doctrine is ‘alive and well in Louisiana’ and prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action.” However, defendants fail to discuss that the Third Circuit made this statement in the context of its analysis of La. 2018In Guilbeau v. Domingues , 14-328, p. 7 (La.App. 3 Cir. 10/1/14), 149 So.3d 825 , 829, writ denied , 14-2283 (La. 1/16/15), 157 So.3d 1132 , this court noted that "the clean hands doctrine ... prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action." In J-W Operating Co. v. Olsen , 49,925, p. 22 (La.App. 2 Cir. 6/24/15), 167 So.3d 1123 , 1135, the second circuit recognized that pursuant to La.Civ.Code art. 2033, a person who knows "at the time of contracting of the defect that made the contract absolutely	3	2018–2022
Guilbeau v. Domingues neutral la · 2015 2 sentences 2022App. 3 Cir. 10/1/14), 149 So.3d 825, 829 , writ denied, 14-2283 (La. 1/16/15), 157 So.3d 1132 , for its statement that “the clean hands doctrine is ‘alive and well in Louisiana’ and prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action.” However, defendants fail to discuss that the Third Circuit made this statement in the context of its analysis of La. 2018In Guilbeau v. Domingues , 14-328, p. 7 (La.App. 3 Cir. 10/1/14), 149 So.3d 825 , 829, writ denied , 14-2283 (La. 1/16/15), 157 So.3d 1132 , this court noted that "the clean hands doctrine ... prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action." In J-W Operating Co. v. Olsen , 49,925, p. 22 (La.App. 2 Cir. 6/24/15), 167 So.3d 1123 , 1135, the second circuit recognized that pursuant to La.Civ.Code art. 2033, a person who knows "at the time of contracting of the defect that made the contract absolutely	3	2018–2022
Dugas v. Dugas green lactapp · 2001 2 sentences 2018In Guilbeau v. Domingues , 14-328, p. 7 (La.App. 3 Cir. 10/1/14), 149 So.3d 825 , 829, writ denied , 14-2283 (La. 1/16/15), 157 So.3d 1132 , this court noted that "the clean hands doctrine ... prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action." In J-W Operating Co. v. Olsen , 49,925, p. 22 (La.App. 2 Cir. 6/24/15), 167 So.3d 1123 , 1135, the second circuit recognized that pursuant to La.Civ.Code art. 2033, a person who knows "at the time of contracting of the defect that made the contract absolutely 2018In Guilbeau v. Domingues , 14-328, p. 7 (La.App. 3 Cir. 10/1/14), 149 So.3d 825 , 829, writ denied , 14-2283 (La. 1/16/15), 157 So.3d 1132 , this court noted that "the clean hands doctrine ... prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action." In J-W Operating Co. v. Olsen , 49,925, p. 22 (La.App. 2 Cir. 6/24/15), 167 So.3d 1123 , 1135, the second circuit recognized that pursuant to La.Civ.Code art. 2033, a person who knows "at the time of contracting of the defect that made the contract absolutely	2	2018–2018
Dugas v. Dugas neutral la · 2002 2 sentences 2018In Guilbeau v. Domingues , 14-328, p. 7 (La.App. 3 Cir. 10/1/14), 149 So.3d 825 , 829, writ denied , 14-2283 (La. 1/16/15), 157 So.3d 1132 , this court noted that "the clean hands doctrine ... prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action." In J-W Operating Co. v. Olsen , 49,925, p. 22 (La.App. 2 Cir. 6/24/15), 167 So.3d 1123 , 1135, the second circuit recognized that pursuant to La.Civ.Code art. 2033, a person who knows "at the time of contracting of the defect that made the contract absolutely 2018In Guilbeau v. Domingues , 14-328, p. 7 (La.App. 3 Cir. 10/1/14), 149 So.3d 825 , 829, writ denied , 14-2283 (La. 1/16/15), 157 So.3d 1132 , this court noted that "the clean hands doctrine ... prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action." In J-W Operating Co. v. Olsen , 49,925, p. 22 (La.App. 2 Cir. 6/24/15), 167 So.3d 1123 , 1135, the second circuit recognized that pursuant to La.Civ.Code art. 2033, a person who knows "at the time of contracting of the defect that made the contract absolutely	2	2018–2018
J-W Operating Co. v. Olsen neutral lactapp · 2015 2 sentences 2018In Guilbeau v. Domingues , 14-328, p. 7 (La.App. 3 Cir. 10/1/14), 149 So.3d 825 , 829, writ denied , 14-2283 (La. 1/16/15), 157 So.3d 1132 , this court noted that "the clean hands doctrine ... prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action." In J-W Operating Co. v. Olsen , 49,925, p. 22 (La.App. 2 Cir. 6/24/15), 167 So.3d 1123 , 1135, the second circuit recognized that pursuant to La.Civ.Code art. 2033, a person who knows "at the time of contracting of the defect that made the contract absolutely 2018In Guilbeau v. Domingues , 14-328, p. 7 (La.App. 3 Cir. 10/1/14), 149 So.3d 825 , 829, writ denied , 14-2283 (La. 1/16/15), 157 So.3d 1132 , this court noted that "the clean hands doctrine ... prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action." In J-W Operating Co. v. Olsen , 49,925, p. 22 (La.App. 2 Cir. 6/24/15), 167 So.3d 1123 , 1135, the second circuit recognized that pursuant to La.Civ.Code art. 2033, a person who knows "at the time of contracting of the defect that made the contract absolutely	2	2018–2018
Lakewood Property Owners' Ass'n v. Kyle neutral lactapp · 2015 2 sentences 2018Owners' Ass'n v. Smith , 14-1376, 15-178, p. 19 (La.App. 4 Cir. 12/23/15), 183 So.3d 780 , 792, writ denied , 16-138 (La. 2/26/16), 187 So.3d 469 . 2018Owners' Ass'n v. Smith , 14-1376, 15-178, p. 19 (La.App. 4 Cir. 12/23/15), 183 So.3d 780 , 792, writ denied , 16-138 (La. 2/26/16), 187 So.3d 469 .	2	2018–2018
State v. Senegal neutral la · 2016 2 sentences 2018Owners' Ass'n v. Smith , 14-1376, 15-178, p. 19 (La.App. 4 Cir. 12/23/15), 183 So.3d 780 , 792, writ denied , 16-138 (La. 2/26/16), 187 So.3d 469 . 2018Owners' Ass'n v. Smith , 14-1376, 15-178, p. 19 (La.App. 4 Cir. 12/23/15), 183 So.3d 780 , 792, writ denied , 16-138 (La. 2/26/16), 187 So.3d 469 .	2	2018–2018
REDAR, LLC v. Rush green lactapp · 2010 2 sentences 2014Redar, L.L.C. v. Rush, 09-1417 (La.App. 3rd Cir.11/17/10), 51 So.3d 859 . \|17In this case, Samson has not shown that Mark Smith knowingly received excess royalties during the period after the 1996 donation was annulled. 2014As we explained in Redar, LLC v. Rush, 09-1417, p. 11 (La.App. 3 Cir. 11/17/10), 51 So.3d 859, 868 , writs denied, 10-2784, 10-2832, 10-2833,10-2869 (La.3/25/11), 61 So.3d 662 (citing Griffith v. Latiolais, 09-824, pp. 24-25 (La.App. 3 Cir. 3/3/10) , 32 So.2d 380, 396 , reversed in part on other grounds, 10-754 (La.10/19/10), 48 So.3d 1058 ), the clean hands doctrine is “ ‘alive and well in Louisiana’ ” and prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action.	2	2014–2014
City of New Orleans v. Bd. of Dir. of State Museum green la · 1999 1 sentence 2022The court recognized that a “party who seeks equitable relief, must not be pari delicto; that is, he himself must be free from any unlawful or inequitable conduct with respect to the matter or transaction in question.” Id. [Emphasis added.] More recently, in Cimarex Energy Co. v. Mauboules, 09-1170, 09-1180, 09- 1194 (La. 4/9/10), 40 So.3d 931, 945 , the Supreme Court quoted the language cited above from City of New Orleans v. Levy, supra, regarding the equitable nature of the unclean hands doctrine and declined to find that the plaintiff violated the clean hands doctrine, or otherwise acted i	1	2022–2022
ALLVEND v. Payphone Commissions Co., Inc. green lactapp · 2001 1 sentence 2015Allvend, Inc. v. Payphone Commissions Co., 00-0661, p. 6 (La.App. 4 Cir. 5/23/01), 804 So.2d 27, 30 .	1	2015–2015
Matthews v. Sun Exploration and Production green lactapp · 1988 1 sentence 2014O’Neal v. JLH Enter prises, Inc., 37,432 (La.App.2d Cir.12/1/03), 862 So.2d 1021 ; Matthews, supra. Under the clean hands doctrine, a person cannot maintain an action if, in order to establish his cause of action, he must rely on any illegal or immoral act or transaction to which he is a part.	1	2014–2014
United Financial Services of Baton Rouge, Inc. v. Guste green lactapp · 1989 1 sentence 2014United Financial, supra. Even if Mr. Pannagl did not have “clean hands” with regard to his domestic litigation with his wife, Mr. Kelly has failed to allege, assert, or show that Mr. Pannagl engaged in any fraud or misrepresentation relative to the instant transaction or litigation.	1	2014–2014
O'NEAL v. JLH Enterprises, Inc. neutral lactapp · 2003 1 sentence 2014O’Neal v. JLH Enter prises, Inc., 37,432 (La.App.2d Cir.12/1/03), 862 So.2d 1021 ; Matthews, supra. Under the clean hands doctrine, a person cannot maintain an action if, in order to establish his cause of action, he must rely on any illegal or immoral act or transaction to which he is a part.	1	2014–2014
Griffith v. Latiolais green la · 2010 1 sentence 2014As we explained in Redar, LLC v. Rush, 09-1417, p. 11 (La.App. 3 Cir. 11/17/10), 51 So.3d 859, 868 , writs denied, 10-2784, 10-2832, 10-2833,10-2869 (La.3/25/11), 61 So.3d 662 (citing Griffith v. Latiolais, 09-824, pp. 24-25 (La.App. 3 Cir. 3/3/10) , 32 So.2d 380, 396 , reversed in part on other grounds, 10-754 (La.10/19/10), 48 So.3d 1058 ), the clean hands doctrine is “ ‘alive and well in Louisiana’ ” and prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action.	1	2014–2014
Allen v. Wilson neutral ca9 · 1947 1 sentence 2014As we explained in Redar, LLC v. Rush, 09-1417, p. 11 (La.App. 3 Cir. 11/17/10), 51 So.3d 859, 868 , writs denied, 10-2784, 10-2832, 10-2833,10-2869 (La.3/25/11), 61 So.3d 662 (citing Griffith v. Latiolais, 09-824, pp. 24-25 (La.App. 3 Cir. 3/3/10) , 32 So.2d 380, 396 , reversed in part on other grounds, 10-754 (La.10/19/10), 48 So.3d 1058 ), the clean hands doctrine is “ ‘alive and well in Louisiana’ ” and prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action.	1	2014–2014
REDAR, LLC v. Rush neutral la · 2011 1 sentence 2014As we explained in Redar, LLC v. Rush, 09-1417, p. 11 (La.App. 3 Cir. 11/17/10), 51 So.3d 859, 868 , writs denied, 10-2784, 10-2832, 10-2833,10-2869 (La.3/25/11), 61 So.3d 662 (citing Griffith v. Latiolais, 09-824, pp. 24-25 (La.App. 3 Cir. 3/3/10) , 32 So.2d 380, 396 , reversed in part on other grounds, 10-754 (La.10/19/10), 48 So.3d 1058 ), the clean hands doctrine is “ ‘alive and well in Louisiana’ ” and prevents a litigant from maintaining an action if he must rely, even partially, on his own illicit or immoral act to establish a cause of action.	1	2014–2014

Where else courts name it

CT 63 (1949–2025) MS 43 (1938–2026) AL 37 (1981–2025) MI 28 (1940–2025) TX 27 (1956–2020) CA 27 (1943–2023) MD 25 (1952–2023) NJ 17 (1934–2008) FL 17 (1946–2010) AR 16 (1939–2022) OH 15 (1960–2024) KS 15 (1975–2025) IL 14 (1919–2023) ID 12 (1983–2024) PA 12 (1953–2020) NY 12 (1941–1992) OR 10 (1967–2021) LA 10 (2014–2023) WI 9 (1981–2024) NC 7 (1982–2022) VA 7 (1990–2024) IA 6 (1995–2023) MO 6 (1969–1989) MT 5 (1955–2008) TN 5 (1977–2013) CO 5 (1993–2016) ME 5 (1990–2015) DC 4 (1970–2021) IN 4 (1969–2025) WV 4 (1931–2024) AZ 4 (1963–2010) UT 3 (2009–2024) HI 3 (2006–2011) NE 3 (1983–1992) GA 3 (1987–2006) WA 3 (1979–2017) DE 2 (1971–1998) OK 2 (2002–2005)

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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