Kentucky has long recognized the same core tenets. See, e.g., Damron v. Call, 225 Ky. 150, 7 S.W.2d 1069, 1069 (1928) (explaining "Courts of equity do not lend themselves to the aid of wrongdoers who are in pari delicto. They will neither enforce an executory contract nor relieve from the consequences of an executed contract founded upon an illegal consideration, if the parties be in pari delicto.
The rule is universally applied. Barnell v. Jacobs et al., 304 Ky. 374, 200 S.W.2d 940; McGhee's Adm'r v. Elcomb Coal Co., 288 Ky. 540, 156 S.W. 21d 868; Sparks v. Baker, 272 Ky. 663, 114 S.W.2d 1145; Damron v. Call, 225 Ky. 150, 7 S.W.2d 1069; Restatement of Contracts, vol. 2, section 598; 17 C.J.S., Contracts, sec. 272. Appellant cites a number of foreign cases, including Stryk v. Mnichowicz, 167 Wisc. 265, 167 N.W. 246, 1 A.L.R. 297, which held that where a person is induced by the false representation of another to do an act which in consequence of such misrepresentation he, without negligence on his part, believes to be neither illegal nor immoral and which would not be illegal or immoral if the representation were true, but which is in fact a criminal offense, he may recover from the maker of the representation any damages sustained by him proximately resulting from the act.
We will cite only a few of these cases. Coleman v. Coleman, 147 Ky. 383, 144 S.W. 1, 39 L.R.A., N.S., 193; Shamo v. Benjamin's Admr., 155 Ky. 373, 159 S.W. 798; Carson v. Beliles, 121 Ky. 294, 89 S.W. 208, 28 Ky. Law Rep. 272, 1 L.R.A., N.S., 1007; Ballance v. Ballance, 213 Ky. 73, 280 S.W. 473; Stiefvater v. Stiefvater, 246 Ky. 646, 53 S.W.2d 926; Damron v. Call, 225 Ky. 150, 7 S.W.2d 1069; Coffey v. Coffey, 232 Ky. 179, 22 S.W.2d 589. It was written in Harper v. Harper, 85 Ky. 160, 161, 3 S.W. 5, 7 Am. St. Rep. 583, that where a person was frightened or intimidated into making a fraudulent conveyance, equity will grant relief since the parties were not in pari delicto, and this case has been followed down to the present.
" Passing over intervening cases applying this principle, we may cite the later ones of Fears v. United Loan Deposit Bank, 172 Ky. 255, 189 S.W. 226; Mounts v. Charles, 187 Ky. 421, 219 S.W. 184; Thompson v. Thompson, 188 Ky. 811, 224 S.W. 350; Damron v. Call, 225 Ky. 150, 7 S.W.2d 1069. The foregoing statements and decisions are rested upon facts and conditions showing the participating parties to have been of equal guilt.