Setayesh Padideh v. Ramin Moradi, D.D.S., et al.

Summary

**Key Legal Topics:** Unclean hands defense in malicious prosecution actions; three-pronged *Blain* test; sufficiency of evidence for defense; standard of review (independent for analogous-case-law prong, substantial evidence for nature-of-misconduct and relationship prongs). **Holding:** The court affirmed that unclean hands may bar a malicious prosecution claim where the plaintiff gave false or misleading deposition testimony in the underlying action, and the defendant made strategic litigation decisions in reliance on that testimony. The court held that the defense does not require proof that the defendant would have prevailed in the underlying action absent the misconduct, as long as the misconduct directly relates to the transaction and affects the equitable relations between the parties.

Holdings

1. Yes, because all three prongs of the Blain test were met.

Questions Presented

1. Whether the unclean hands defense was properly applied to bar Padideh's malicious prosecution claim.
2. Whether the three prongs of the Blain test were satisfied.
3. Whether additional prejudice or causation showing is required for the unclean hands defense in malicious prosecution actions.

Disposition

Affirmed as to respondent Kamarei; appeal dismissed as to respondent Moradi.