## Facts

- Thomas G. Hicks and Cindy Gilbert cohabited for about twelve years and in 1989 acquired real property in Golden Beach, Maryland, as joint tenants.
- Hicks alleged he contributed money, time, and labor to construct a home on the property, which became the couple’s primary asset.
- In 1991–1992, facing substantial debt and anticipating potential creditor action, Hicks and Cindy conveyed the property to Cindy and her parents, Aaron and Sara Gilbert.
- In his complaint, Hicks alleged the conveyance was made to prevent attachment of the property for Hicks’s debts that had not been reduced to judgment.
- Hicks asserted the transferees paid no consideration and that an oral agreement existed to compensate him for his contributions if the property were sold; the Gilberts disputed these allegations.
- Hicks later restructured and paid his debts, continued living on the property, and paid expenses until the relationship ended in 1998.
- After Cindy refused Hicks’s request for reimbursement, Cindy and her parents conveyed the property to Cindy’s brother for $50,000.
- Hicks sued seeking equitable remedies including unjust enrichment, promissory estoppel, lis pendens, and relief setting aside the conveyance.

## Issues

1. Whether the doctrine of unclean hands barred Hicks’s equitable claims as a matter of law where his own pleadings admitted participation in a conveyance intended to hinder potential creditors.
2. Whether Hicks’s later repayment of his debts “purged” the earlier misconduct so that equity could entertain his claims.

## Decision

- The Court of Special Appeals of Maryland affirmed summary judgment for Cindy Gilbert and her parents.
- The court held Hicks’s admitted purpose in transferring the property to avoid creditor attachment constituted inequitable conduct directly related to the transaction underlying his requested equitable relief.
- The court held subsequent repayment of creditors did not remove the unclean-hands bar because the challenged, creditor-avoidance transfer remained the basis of Hicks’s claims.

## Legal Principles

- Equity will deny relief to a plaintiff whose misconduct regarding the matter in dispute is fraudulent or otherwise unconscionable, to protect the integrity of the judicial process.
- The unclean-hands doctrine applies when the plaintiff’s improper conduct is directly connected to the transaction or subject matter for which equitable relief is sought, not when it is merely collateral.
- A plaintiff may be barred on summary judgment when the essential inequitable conduct is established by undisputed facts, including admissions in the plaintiff’s own pleadings.
- Later repayment of debts does not “cleanse” a conveyance undertaken to hinder creditors when the plaintiff seeks equitable benefits flowing from that same conveyance.

## Conclusion

Because Hicks admitted he transferred the property to keep it from potential creditors and then sought equitable relief tied to that transaction, the court held he came to equity with unclean hands and could not proceed, even though he later satisfied his debts.


Hicks v. Gilbert, 762 A.2d 986 (Md. Ct. Spec. App. 2000)