"While there was some initial reluctance to apply the unclean hands doctrine to enforcement suits brought under ERISA, 'because its application would significantly harm innocent parties, namely, participants and beneficiaries,' federal courts have considered and applied the doctrine of unclean hands to bar a plaintiff's recovery in an ERISA action. If a claim is equitable in nature under ERISA Section 502(a)(3), the unclean hands doctrine is available as a defense. "  MORE >>