In the Matter of Watkins (2017) & "Unclean Hands" in Estate Administration

The doctrine of “unclean hands” is a common law concept which, at its core, is concerned with ensuring that the spirit of the law is followed. The doctrine can be summed up as follows: if someone behaves in an improper fashion, and by way of that behavior gains a legal right, that person is barred from asserting that right and acquiring any benefits which might otherwise follow. There must be a clear connection between the improper conduct and the acquisition of the right; simply because someone acts improperly isn’t enough to raise the unclean hands doctrine, there must be an undeniably clear association between the conduct and the right acquired.

The doctrine of unclean hands was brought up for the first time in an estate or inheritance context in the case of In the Matter of Watkins (2017). Although this scenario might be rare, we can still take important lessons from this case about the unclean hands doctrine and how it operates in a real world situation. Let’s go over this case in detail.

Facts of the Case

The decedent in this case was an older gentleman who had already been divorced twice before meeting the appellant. The appellant was a much younger woman who became acquainted with the decedent while he was still married to his second wife. The decedent’s second wife became terminally ill and passed away in 2012, shortly before the decedent began seeing the appellant romantically.  

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The decedent and the appellant were married soon after the decedent’s second wife passed away; immediately, the decedent’s children (one from his first marriage, and another from his second marriage) suspected that the appellant had exercised “undue influence” in convincing the decedent to marry her. The decedent’s emotional condition following the death of his second wife was not healthy; plus, his mental acuity was declining. Hence, there was suspicion that the appellant used undue influence to procure the marriage for her own selfish purposes.

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Events which occurred after the marriage seemed to support the suspicions of the decedent’s children. The decedent purchased lavish gifts for the appellant, frequently engaged in excessive or reckless spending, and seemed to lack his typical financial intelligence. He also showed signs of diminished mental capacity in general (i.e. forgetfulness, absentmindedness, etc.). The decedent was a very wealthy businessman and had a considerable net worth at the time of his passing. When the decedent eventually passed away in 2014, the appellate attempted to the “elective share” of 1/3rd of the decedent’s estate.

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Ruling & Discussion

After losing at the trial court level, the decedent’s wife then filed an appeal. There were several issues brought up during the appeal, including the applicability of a Florida statute. The decedent had passed away in Florida, and so there were legal issues surrounding jurisdiction and the applicability of Florida’s statute on this matter. Although the appellate division concurred with the appellant that the Florida statute didn’t apply (because the decedent was domiciled in Maryland), ultimately this issue didn’t alter the court’s determination regarding the availability of the elective share.  

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Because the appellate division held that the appellant had indeed procured the marriage through undue influence, the doctrine of unclean hands was invoked, which meant that the elective share was barred. Again, this was the first time Maryland had dealt with unclean hands in the context of a surviving spouse attempting to claim an elective share, and so the appellate division referenced persuasive authority from New York. But, in the end, the appellate division found that allowing the appellant to take the share would indeed run against the unclean hands doctrine, as she would be directly benefitting from her improper behavior.

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Contact the Murphy Law Firm for Additional Information

If readers want to learn more about estate administration in Maryland, the probate process, creating a valid last will and testament, or any other related matter, contact one of the estate planning attorneys at the Murphy Law Firm by calling 240-219-5243.