Law360, New York ( July 28, 2015, 11:07 AM EDT) -- On July 7, 2015, the United States Court of Appeals for the Seventh Circuit issued a decision affirming the dismissal of a bankruptcy trustee's Illinois law accounting malpractice claims against the investment funds' pre-bankruptcy auditor on the grounds of in pari delicto. Peterson v. McGladrey LLP, No. 14-1986, (7th Cir. July 7, 2015). This decision is significant in that it establishes the potential viability of the in pari delicto doctrine as a defense to claims of a bankrupt estate against its pre-bankruptcy advisers and auditors even in cases where the alleged failures of the defendant professionals go beyond merely failing to discover the wrongful acts of the debtor or its pre-bankruptcy management....