The Eighth Circuit held today that a bankruptcy trustee has standing to sue third parties for harm to the debtor in bankruptcy despite a possible in pari delicto defense. The court rejected the Second Circuit’s approach, which treats in pari delicto as a standing-killer. In re Senior Cottages of Am., LLC (Moratzka v. Morris), No. 05-3867 (8th Cir. Apr. 2, 2007) (applying Minnesota law).