clean hands doctrine (Iowa) · Go Syfert
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clean hands doctrine in Iowa

6 Iowa opinions name it 2 courts 1995–2023 1 in the last five years

The cases below were cited by Iowa 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 (9)

CaseFollowedCited
Ellwood v. Mid States Commodities, Inc.green
iowa · 1987 · cited in 3 Iowa opinions naming this issue, 2017–2023
2 sentences

2023“The clean hands doctrine stands for the principle that a party may be denied relief in equity based on his inequitable, unfair, dishonest, fraudulent, or deceitful conduct.” Ellwood v. Mid States Commodities, Inc., 404 N.W.2d 174, 184 (Iowa 1987).

2020See Ellwood v. Mid States Commodities, Inc., 404 N.W.2d 174, 184 (Iowa 1987) (“The clean hands doctrine stands for the principle that a party may be denied relief in equity based on his inequitable, unfair, dishonest, fraudulent, or deceitful conduct.”).

33
Butler v. Butlergreen
iowa · 1962 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023Assocs., Inc., 178 N.W.2d 343, 353 (Iowa 1970); see also Hora v. Hora, No. 22-0259, 2023 WL 1809035 , at *6 (Iowa Ct. App. Feb. 8, 2023) (noting the clean hands doctrine “is 18 not a favored doctrine of the courts”); JP Morgan Chase Bank, Nat’l Ass’n v. Ackley, No. 12-1338, 2013 WL 1749783 , at *1 (Iowa Ct. App. Apr. 24, 2013) (“The defense of the clean hands doctrine is not favored by the courts.”); Butler v. Butler, 114 N.W.2d 595, 619 (Iowa 1962) (same). “[T]he application of the doctrine is purely discretionary and . . . it should not be applied where the result would be contrary to public

11
Anita Valley, Inc. v. Bingleygreen
iowa · 1979 · cited in 1 Iowa opinions naming this issue, 2023–2023
1 sentence

2023The doctrine “requires proof that the plaintiff ‘dirtied [his hands] in acquiring the rights he now asserts.’” Hora, 2023 WL 1809035 , at *6 (quoting Anita Valley, Inc. v. Bingley, 279 N.W.2d 37, 41 (Iowa 1979)).

11
Cedar Memorial Park Cemetery Ass'n v. Personnel Associates Inc.green
iowa · 1970 · cited in 1 Iowa opinions naming this issue, 2023–2023
2 sentences

2023Assocs., Inc., 178 N.W.2d 343, 353 (Iowa 1970); see also Hora v. Hora, No. 22-0259, 2023 WL 1809035 , at *6 (Iowa Ct. App. Feb. 8, 2023) (noting the clean hands doctrine “is 18 not a favored doctrine of the courts”); JP Morgan Chase Bank, Nat’l Ass’n v. Ackley, No. 12-1338, 2013 WL 1749783 , at *1 (Iowa Ct. App. Apr. 24, 2013) (“The defense of the clean hands doctrine is not favored by the courts.”); Butler v. Butler, 114 N.W.2d 595, 619 (Iowa 1962) (same). “[T]he application of the doctrine is purely discretionary and . . . it should not be applied where the result would be contrary to public

2023Assocs., Inc., 178 N.W.2d 343, 353 (Iowa 1970); see also Hora v. Hora, No. 22-0259, 2023 WL 1809035 , at *6 (Iowa Ct. App. Feb. 8, 2023) (noting the clean hands doctrine “is 18 not a favored doctrine of the courts”); JP Morgan Chase Bank, Nat’l Ass’n v. Ackley, No. 12-1338, 2013 WL 1749783 , at *1 (Iowa Ct. App. Apr. 24, 2013) (“The defense of the clean hands doctrine is not favored by the courts.”); Butler v. Butler, 114 N.W.2d 595, 619 (Iowa 1962) (same). “[T]he application of the doctrine is purely discretionary and . . . it should not be applied where the result would be contrary to public

11
Opperman v. M. & I. DEHY, INC.green
iowa · 2002 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020Dehy, Inc., 644 N.W.2d 1, 6 (Iowa 2002) (quoting 27A Am.

11
Jacquelyn M. Quint v. A.E. Staley Manufacturing Company, Jacquelyn M. Quint v. A.E. Staley Manufacturing Companygreen
ca1 · 1999 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020We decline to apply that equitable principle here, particularly because we affirm the finding Casey’s was not authorized to test McCann. 27 for back pay for the “utter failure” to seek similar employment. 172 F.3d 1, 16 (1st Cir. 1999).

11
Clark v. Thompsongreen
iowa · 1873 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020See Clark v. Thompson, 37 Iowa 536, 540 (1873) (“It is not within the jurisdiction of equity to set aside statutes, and we have never heard that it has power to relieve, in any way, the severities of express legislative enactments.”).

11
Phipps v. Winneshiek Countygreen
iowa · 1999 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019“A claim of false testimony constitutes intrinsic fraud.” Phipps v. Winneshiek Cty., 593 N.W.2d 143, 146 (Iowa 1999).

11
Forkin Ex Rel. Harrison Park Development, Inc. v. Colegreen
illappct · 1989 · cited in 1 Iowa opinions naming this issue, 2017–2017
2 sentences

2017See Ellwood v. Mid States 9 Commodities, Inc., 404 N.W.2d 174, 184 (Iowa 1987) (noting the doctrine of clean hands may be applied in actions brought in equity). “[E]quity requires that a shareholder derivative action cannot be maintained if the nominal plaintiff has unclean hands in connection with the transactions which are the bases for the litigation or has participated or acquiesced in, or benefited from the conduct of which he now complains.” Forkin v. Cole, 548 N.E.2d 795, 805 (Ill.

2017See Ellwood v. Mid States 9 Commodities, Inc., 404 N.W.2d 174, 184 (Iowa 1987) (noting the doctrine of clean hands may be applied in actions brought in equity). “[E]quity requires that a shareholder derivative action cannot be maintained if the nominal plaintiff has unclean hands in connection with the transactions which are the bases for the litigation or has participated or acquiesced in, or benefited from the conduct of which he now complains.” Forkin v. Cole, 548 N.E.2d 795, 805 (Ill.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
McKennon v. Nashville Banner Publishing Co. green
scotus · 1995
2 sentences

1995McKennon , 513 U.S. at -, 115 S.Ct. at 885 , 130 L.Ed.2d at 863 .

1995McKennon , 513 U.S. at -, 115 S.Ct. at 885 , 130 L.Ed.2d at 863 .

11995–1995

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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