In a foreclosure action, the Connecticut Supreme Court affirmed that special defenses and counterclaims related to the making, validity or enforcement of the mortgage are not subject to a more rigorous test than any other civil case.

The defendant, Robert L. Lewis, appealed the judgment of foreclosure by sale, and claimed the trial court’s decision to strike two of his special defenses—unclean hands and breach of the implied covenant of good faith and fair dealing—was incorrect.