Kendall-Jackson Winery, Ltd. v. Superior Court

In Kendall-Jackson Winery, Ltd. v. Superior Court (1999) 76 Cal.App.4th 970, this court stated: "The defense of unclean hands arises from the maxim, '"'He who comes into Equity must come with clean hands.'"' The doctrine demands that a plaintiff act fairly in the matter for which he seeks a remedy. He must come into court with clean hands, and keep them clean, or he will be denied relief, regardless of the merits of his claim. The defense is available in legal as well as equitable actions. Whether the doctrine of unclean hands applies is a question of fact. "The unclean hands doctrine protects judicial integrity and promotes justice. It protects judicial integrity because allowing a plaintiff with unclean hands to recover in an action creates doubts as to the justice provided by the judicial system. Thus, precluding recovery to the unclean plaintiff protects the court's, rather than the opposing party's, interests. The doctrine promotes justice by making a plaintiff answer for his own misconduct in the action. It prevents 'a wrongdoer from enjoying the fruits of his transgression.' "Not every wrongful act constitutes unclean hands. But, the misconduct need not be a crime or an actionable tort. Any conduct that violates conscience, or good faith, or other equitable standards of conduct is sufficient cause to invoke the doctrine. " (Kendall-Jackson Winery, Ltd. v. Superior Court, supra, 76 Cal.App.4th at pp. 978-979.)