How To Prove A California Unclean Hands Defense

 

How To Prove A California Unclean Hands Defense

 

In California, a defense of Unclean Hands is defined as:

The doctrine of Unclean Hands is based on the principle that a party who seeks relief from a court should not have engaged in wrongful or unethical conduct related to the same matter. The unclean hands defense operates on the principle of “he who comes into equity must come with clean hands.” Therefore, the defendant must argue that it would be unjust for the plaintiff to receive equitable relief (such as injunctive relief, specific performance, or equitable remedies) due to their own misconduct.

It simply means:

A party cannot bring a lawsuit about something that they also played a part in.

There are 3 elements of the defense:

  • Element 1. The plaintiff engaged in wrongful, unfair, or inequitable conduct related to the subject matter of the lawsuit. The plaintiff acted unfairly or dishonestly in a way that relates to the issue at hand in the lawsuit, which means they can’t expect to win their case because their own bad behavior undermines their claims.

    Facts that might support this element look like:

    * The plaintiff knowingly submitted false evidence to the court to support their claims, undermining the integrity of the judicial process.
    * The plaintiff engaged in deceptive practices by concealing material facts that would have significantly affected the outcome of the case.
    * The plaintiff has a history of similar misconduct in previous legal matters, demonstrating a pattern of unfair behavior.
    * The plaintiff attempted to coerce witnesses into providing false testimony to bolster their case, compromising the fairness of the proceedings.
    * The plaintiff failed to disclose a prior settlement agreement related to the same issue, which is relevant to the current lawsuit.

  • Element 2. There was a causal connection between the plaintiff’s wrongful conduct and the subject matter of the lawsuit. The plaintiff’s bad behavior directly relates to the issue at hand in the lawsuit, meaning their own wrongful actions are linked to the case they’re trying to win, which can weaken their position.

    Facts that might support this element look like:

    * The plaintiff knowingly engaged in fraudulent activities that directly impacted the financial transactions at issue in the lawsuit.
    * Evidence shows that the plaintiff falsified documents to gain an unfair advantage in the contractual agreement being disputed.
    * The plaintiff’s misconduct created a situation that led to the damages claimed in the lawsuit, establishing a direct link between their actions and the alleged harm.
    * Testimony reveals that the plaintiff’s deceptive practices were a significant factor in the breakdown of negotiations, resulting in the current legal dispute.
    * The plaintiff’s wrongful conduct was not only intentional but also directly interfered with the defendant’s ability to fulfill their contractual obligations.

  • Element 3. Allowing the plaintiff to pursue their claims would result in an unfair or inequitable outcome. Allowing the plaintiff to continue with their claims would lead to an unjust situation because they have acted improperly or dishonestly in relation to the issue at hand, making it unfair for them to seek a legal remedy.

    Facts that might support this element look like:

    * The plaintiff knowingly engaged in fraudulent behavior by misrepresenting key facts during negotiations, undermining the integrity of the transaction.
    * The plaintiff has benefited from their own wrongful conduct, receiving financial gains while disregarding contractual obligations.
    * The plaintiff’s actions have caused significant harm to the defendant, creating an imbalance that would be exacerbated by allowing the claims to proceed.
    * The plaintiff has repeatedly violated industry regulations, demonstrating a pattern of unethical behavior that contradicts their claims for relief.
    * Allowing the plaintiff to pursue their claims would reward their misconduct, setting a dangerous precedent for future cases.

(See California Civil Code Section 3517. Peregrine Funding, Inc. v. Sheppard Mullin Richter & Hampton LLP (2005) 133 Cal.App.4th 658, 676.)
If you’re in court without a lawyer and plan to assert a Defense of Unclean Hands, it’s essential to engage in a Personal Practice of Law. You’ll need to determine what to file at each phase of your case and prepare legal documents that are supported by thorough legal research and a strong analysis of the facts. This proactive approach will help you effectively present your Defense of Unclean Hands in court.

Prove Your CA Unclean Hands Defense

U.S. Civil Cases Only

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