"Unclean Hands: Everything You Need to Know". UpCounsel. 2020-10-23. Retrieved 2022-11-04. ("Note that the plaintiff can also use the unclean hands defense. Specifically, the plaintiff could argue that the defendant isn't entitled to another type of defense due to his or her unclean hands")
"Unclean Hands Doctrine". Practical Law. 2022-09-15. Retrieved 2022-11-04. ("Although the unclean hands doctrine is typically an affirmative defense asserted by a defendant, it may also be asserted by a plaintiff in opposition to an equitable defense such as estoppel")
