Andre Flowers v. Dancy

Opinion

DUARTE, J.

The “unclean hands” doctrine is often invoked but rarely applicable. We publish this case because it illustrates a proper application of that doctrine—and Civil Code section 3543 (section 3543), a related maxim of jurisprudence—to preclude a party from attacking an admittedly forged deed.

Augustus Collins and Elijah Flowers were brothers-in-law who jointly owned a house.1 Elijah’s son Joseph Flowers (not a party herein) had once been on the title to the house, and after Elijah and Augustus died, he apparently forged their signatures on a deed purporting to transfer the house…