In Bein v. Heath (1848) 47 U.S. 228, the Supreme Court recognized that: "The equitable powers of this court can never be exerted in behalf of one who has acted fraudulently, or who by deceit or any unfair means has gained an advantage. To aid a party in such a case would make this court the abetter of inequity." The Supreme Court, explaining the rationale behind the doctrine of unclean hands, has stated that "the equitable powers of this court can never be exerted in behalf of one who has acted fraudulently, or who by deceit or any unfair means has gained an advantage. To aid a party in such a case would make this courtthe abettor of iniquity."