In Dolny v. Borck, 61 A.D.3d 817, 2009 NY Slip Op 3129, the plaintiff sought to impose a constructive trust upon certain real property and the defendants moved for summary judgment. The property was conveyed to the defendants in order to place the property beyond the reach of plaintiff's judgment creditors, while the plaintiff retained the beneficial ownership of the premises. The Court found that "given the plaintiff's involvement in the arrangement to convey the property to frustrate his creditors in the collection of their legitimate debts, his claim that the [defendants] should be compelled to convey title to the premises to him pursuant to the terms of that arrangement is barred by the doctrine of unclean hands". Id. at 818.