clean hands doctrine in Virginia

2024See Cline v. Berg, 273 Va. 142, 147 (2007) (quoting Richards v. Musselman, 221 Va. -4- assignment of error resolves this case, we do not address Bailey’s remaining assignments of error.9 ANALYSIS Bailey’s petition for relief from unlawful exclusion is brought pursuant to Code § 55.1-1243.1(A)(i).

2022Under the equitable clean hands doctrine, a “complainant seeking equitable relief must not himself have been guilty of any inequitable or wrongful conduct with respect to the . . . subject matter sued on.” Cline v. Berg, 273 Va. 142, 147 (2007); see also Butler v. Hayes, 254 Va. 38, 43 (1997) (“According to a 4 settled equity maxim, a litigant who seeks to invoke an equitable remedy must have clean hands.”), Brown v. Kittle, 225 Va. 451, 456 (1983) (stating the clean hands doctrine is an equitable doctrine by which a party is denied relief because of his own inequitable conduct).

2013The clean hands doctrine requires that “He who comes into equity must come with clean hands....” Richards v. Musselman, 221 Va. 181, 186 , 267 S.E.2d 164, 167 (1980) (quoting W. deFuniak, Handbook of Modem Equity § 24, at 39 (2d ed. 1956)). “[T]he complainant seeking equitable relief must not himself have been guilty of any inequitable or wrongful conduct with respect to the transaction or subject matter sued on.” Id.

2013The clean hands doctrine requires that “He who comes into equity must come with clean hands....” Richards v. Musselman, 221 Va. 181, 186 , 267 S.E.2d 164, 167 (1980) (quoting W. deFuniak, Handbook of Modem Equity § 24, at 39 (2d ed. 1956)). “[T]he complainant seeking equitable relief must not himself have been guilty of any inequitable or wrongful conduct with respect to the transaction or subject matter sued on.” Id.

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).

2022Under the equitable clean hands doctrine, a “complainant seeking equitable relief must not himself have been guilty of any inequitable or wrongful conduct with respect to the . . . subject matter sued on.” Cline v. Berg, 273 Va. 142, 147 (2007); see also Butler v. Hayes, 254 Va. 38, 43 (1997) (“According to a 4 settled equity maxim, a litigant who seeks to invoke an equitable remedy must have clean hands.”), Brown v. Kittle, 225 Va. 451, 456 (1983) (stating the clean hands doctrine is an equitable doctrine by which a party is denied relief because of his own inequitable conduct).

2022Under the equitable clean hands doctrine, a “complainant seeking equitable relief must not himself have been guilty of any inequitable or wrongful conduct with respect to the . . . subject matter sued on.” Cline v. Berg, 273 Va. 142, 147 (2007); see also Butler v. Hayes, 254 Va. 38, 43 (1997) (“According to a 4 settled equity maxim, a litigant who seeks to invoke an equitable remedy must have clean hands.”), Brown v. Kittle, 225 Va. 451, 456 (1983) (stating the clean hands doctrine is an equitable doctrine by which a party is denied relief because of his own inequitable conduct).

2022Under the equitable clean hands doctrine, a “complainant seeking equitable relief must not himself have been guilty of any inequitable or wrongful conduct with respect to the . . . subject matter sued on.” Cline v. Berg, 273 Va. 142, 147 (2007); see also Butler v. Hayes, 254 Va. 38, 43 (1997) (“According to a 4 settled equity maxim, a litigant who seeks to invoke an equitable remedy must have clean hands.”), Brown v. Kittle, 225 Va. 451, 456 (1983) (stating the clean hands doctrine is an equitable doctrine by which a party is denied relief because of his own inequitable conduct).

2022Under the equitable clean hands doctrine, a “complainant seeking equitable relief must not himself have been guilty of any inequitable or wrongful conduct with respect to the . . . subject matter sued on.” Cline v. Berg, 273 Va. 142, 147 (2007); see also Butler v. Hayes, 254 Va. 38, 43 (1997) (“According to a 4 settled equity maxim, a litigant who seeks to invoke an equitable remedy must have clean hands.”), Brown v. Kittle, 225 Va. 451, 456 (1983) (stating the clean hands doctrine is an equitable doctrine by which a party is denied relief because of his own inequitable conduct).