Doctrine of Unclean Hands Maryland
The unclean hands doctrine "refuses recognition and relief from the court to those guilty of unlawful or inequitable conduct pertaining to the matter in which relief is sought." Manown, 89 Md. App. at 511. It is "not applied for the protection of the parties nor as a punishment to the wrongdoer." Adams v. Manown, 328 Md. 463, 474-75, 615 A.2d 611 (1992).
Rather, it protects the integrity of the court and the judicial process by denying relief to those persons "whose very presence before a court is the result of some fraud or inequity." Manown, 89 Md. App. at 511; see also Niner v. Hanson, 217 Md. 298, 309, 142 A.2d 798 (1958).
There must be a nexus between the misconduct and the transaction, because "what is material is not that the plaintiff's hands are dirty, but that he dirties them in acquiring the right he now asserts." Adams, 328 Md. at 476 (citing D. Dobbs, Remedies 2.4 at 46 (1973));
see also Schneider v. Schneider, 96 Md. App. 296, 306, 624 A.2d 1319 (1993) ("It is only when the plaintiff's improper conduct is the source, or part of the source, of his equitable claim, that he is to be barred because of this conduct.").
Since "the doctrine is not one of absolutes," we disturb a trial court's decision to invoke the doctrine only when the court abuses its discretion. Manown, 89 Md. App. at 511.
Summary judgment is appropriate when there is no genuine dispute as to any material fact, and the moving party is entitled to judgment as a matter of law. Md. Rule 2-501(a) (2000).
The trial court does not make findings of fact, but determines only whether a real factual dispute exists. Brown v. Dermer, 357 Md. 344, 354-55, 744 A.2d 47 (2000) (citations omitted); Commercial Union Ins. Co. v. Harleysville Mutual Ins. Co., 110 Md. App. 45, 51, 675 A.2d 1059 (1996).
We review whether the grant of summary judgment was "legally correct." Brown, 357 Md. at 355; Joswick v. Chesapeake Mobile Homes, Inc., 130 Md. App. 493, 498, 747 A.2d 214 (2000) (quoting Harleysville, 110 Md. App. at 51).