Aguayo

INTRODUCTION

Sofia Aguayo appeals a judgment against her and in favor of Michelle Amaro, the special administrator of the estate of Isabel Infante. Sofia 1 and Amaro both sought to quiet title to real property located at 3665 Gillig Avenue in Los Angeles (the property). After a bench trial, the court determined that the property belonged to the estate on the ground that Sofia was barred from asserting adverse possession of the property under the doctrine of unclean hands.

The primary issues on appeal are whether unclean hands can serve as a defense to adverse possession by claim of right and, if so, whether the trial court abused its discretion in applying the defense in this case. We shall conclude that the trial court has discretion to apply the defense of unclean hands when a party claiming adverse possession engages in deceitful interference with the true owner’s ability to defeat the claim, and that the trial court did not abuse its discretion here.

FACTUAL AND PROCEDURAL BACKGROUND

1. The Infante Family Home

Herman Infante and Isabel Infante acquired the property by grant deed in 1946. The property served as the family home for Herman and Isabel and their two…