Case by bankruptcy trustee against corporation's accountants is dismissed

In the case entitled In re:  NM Holdings Company, LLC, the bankruptcy trustee of Venture Holdings Company sued Deloitte & Touche, LLP, alleging that the accountants' annual audits had negligently mis-stated the firm's asset position as a result of self-dealing by the sole shareholder.  This week the Sixth Circuit upheld the dismissal of the suit.  In essence, the Court held that the sole shareholder--who was the officer making improper financial decisions for the entity--was fully aware of his illegal actions and did not rely upon the audits:  therefore the accountants' negligence did not "cause" the deteriorated financial condition (although it may have contributed to the losses suffered by the firm's creditors...).