California, United States of America
The following excerpt is from Dickson, Carlson v. Pole, 83 Cal.App.4th 436, 99 Cal.Rptr.2d 678 (Cal. App. 2000):
A court's discretion to grant an equitable defense such as unclean hands is not unlimited. The court must consider the material facts affecting the equities between the parties; the failure to do so is an abuse of discretion. (Cf. Dorman v. DWLC Corp. (1995) 35 Cal.App.4th 1808, 1815-1817.) If requested, factual findings concerning the nature of the misconduct and the extent of prejudice or damage to the defendant relative to the plaintiff's damages or other requested relief may be necessary to support the court's exercise of discretion and facilitate effective review. (See Code Civ. Proc., 662, 634.) A decision based on bare "equity" unsupported by established precedent and lacking evidentiary support does not disclose the proper exercise of discretion.
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