California, United States of America
The following excerpt is from City Breeze, LLC v. Shahi, B259117 (Cal. App. 2016):
8. There appears to be disagreement as to whether the abuse of discretion or the substantial evidence standard applies to appellate review of a trial court ruling on the unclean hands defense in situations where the defense may legally be raised. (See Brown v. Grimes (2011) 192 Cal.App.4th 265, 275.) The trial court's ruling here is supported under either of those deferential standards.
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