Does the clean hands doctrine apply to bar a putative father's cause of action in a case where the mother became pregnant prior to the age of consent?

In Hines v. Sullivan (1980) 431 N.Y.S.2d 868, 431 N.Y.S.2d 868, the court held that a putative father was precluded from bringing a cause of action under New York law because the "basis of his claim of paternity rest[ed] upon his own wrongdoing." (Id., at p. 870, 431 N.Y.S.2d 868.) The court reasoned that the basis of the suit was the result of the father's wrongdoing because the mother was only 14 or 15 years old when she became pregnant.

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Less than a year later, in LaCroix v. Deyo (1981) 108 Misc.2d 382, 437 N.Y.S.2d 517, a different New York family court refused to apply the clean hands doctrine to bar a putative father's cause of action in a case where the mother became pregnant prior to reaching the age of consent.