Commonwealth Pictures Corporation (Commonwealth) (defendant) contracted to pay McConnell (plaintiff) $10,000, plus a percentage of future box-office receipts, if McConnell could obtain the distribution rights to a new film. McConnell obtained the rights and Commonwealth paid him the $10,000. However, for the next 12 years Commonwealth refused to cut McConnell in on the film’s receipts. McConnell sued in state court. As part of its defense, Commonwealth asserted that, unbeknownst to it at the time, McConnell illegally bribed the producer to obtain the distribution rights. The trial court rejected that defense, ruling that one party’s illegal misconduct in executing a legal contract could not excuse the other party from its contractual obligations. When a lower-level appellate court affirmed, McConnell appealed to the state court of appeals.