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Keywords

trialequitable relief

plaintifftrialunjust enrichmentappellantequitable relief

Related Cases

Fontanarosa v. Connors, Not Reported in N.E. Rptr., 2021 WL 2878412, 2021-Ohio-2346

Facts

Fontanarosa and Connors began their relationship in 2012 while Fontanarosa was still legally married to another woman. He purchased an engagement ring and wedding band for Connors in 2012, and they moved in together shortly thereafter. In 2015, Fontanarosa bought a home, solely funding the purchase, but the deed was in both their names. Their relationship deteriorated, leading to legal disputes over the rings and the home after Fontanarosa filed for partition and replevin.

Fontanarosa married his wife Sue Ellen in 1983. Fontanarosa and his wife separated in 2012. Shortly thereafter he began a relationship with Connors.

Issue

Did the trial court err in concluding that Fontanarosa had unclean hands, thus precluding him from recovering the engagement ring and wedding band?

THE TRIAL COURT ERRED AS A MATTER OF LAW IN CONCLUDING THAT PLAINTIFF/APPELLANT HAD UNCLEAN HANDS PRECLUDING EQUITABLE RELIEF.

Rule

The doctrine of unclean hands bars a party from obtaining equitable relief if they have engaged in reprehensible conduct related to the subject matter of the action.

The defense of unclean hands requires a showing that the party seeking relief engaged in reprehensible conduct with respect to the subject matter of the action.

Analysis

The court found that both parties had unclean hands; Fontanarosa proposed to Connors while still married, and Connors accepted the proposal knowing he was married. This mutual culpability led the magistrate to deny Fontanarosa's claim for the rings, as both parties were deemed to have acted improperly.

The magistrate found that Fontanarosa had “unclean hands” and, therefore, could not recover the rings on a theory of unjust enrichment.

Conclusion

The trial court affirmed the magistrate's decision, ruling in favor of Connors regarding the rings, while Fontanarosa was awarded 100% of the proceeds from the home sale.

Therefore, the court entered judgment in favor of Connors regarding the rings.

Who won?

Connors prevailed regarding the engagement ring and wedding band because the court found both parties had unclean hands, thus denying Fontanarosa's claim for recovery.

The magistrate found that Connors also had “unclean hands” because she accepted a marriage proposal from a man she knew to be married.

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Keywords

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