Parmalat Capital Finance Ltd. v. Grant Thornton International

Dist. Ct. erred in finding that defendant had valid in pari delicto defense against plaintiff’s lawsuit alleging that defendant conducted fraudulent audits of plaintiff’s financial records in violation of Illinois tort law, where Dist. Ct. had acquired case from 2nd Circuit Court of Appeals, which had entered order that directed that matter be transferred to instant Dist. Ct. with directions to remand case to Illinois state court for resolution of lawsuit on merits. Dist. Ct. had no authority to act on merits of case given instant transfer order, even though 2nd Circuit Ct. of Appeals allowed Dist. Ct. to make determination as to whether Illinois court could timely resolve matter, and 2nd Circuit Ct. of Appeals could properly find that Illinois courts would provide more authentic resolution of case that involved purely Illinois law.