Illinois Appellate Court
Civil Court
Illinois Securities Law
(Court opinion corrected 8/18/17.) Under Illinois law, doctrine of in pari delicto does not bar a court-appointed SEC receiver from bringing suit on behalf of a company against the company's outside auditor for allegedly failing to discover fraud and/or illegal acts of the company's sole owner. Under Illinois law, the departure of the fraudulent actor prevents application of in pari delicto defense to a court-appointed SEC receiver's claim against the company's outside auditor. (ROCHFORD and DELORT, concurring.)