Unclean-hands bar to rescission; Equities balancing; Attempted amendment; Standing under the Uniform Voidable Transactions Act (UVTA); Futility of amendment; MCR 2.118(A)(4)

Holding that plaintiff’s equitable rescission claim was barred by unclean hands and that his proposed UVTA amendment was futile, the court affirmed summary disposition for defendants. Plaintiff deeded two houses to defendants (his step-children) in 2018; he later sued to rescind, alleging he transferred them to “‘avoid disclosure to a potential creditor.’” The trial court granted defendants judgment under MCR 2.116(I)(2) and denied plaintiff’s motion to amend. On appeal, the court agreed with the trial court that equity would not aid a party who admits he acted to “conceal and protect [his] assets from potential creditors[,]” noting courts “‘do not lend [their] aid … to assist law violators.’” It also held the amendment was futile: the UVTA provides relief only “as to a creditor,” and plaintiff was not a creditor. He also failed to attach a written proposed pleading as required by MCR 2.118(A)(4).