The Ninth Circuit reversed the dismissal of trustee’s complaint for legal malpractice against a law firm. In re Estate Fin. Mortg. Fund, LLC, Nos. 12-56009, 12-56011 (9th Cir. Mar. 24, 2014). Under California law, a client who engages in wrongdoing in reliance on an attorney’s negligent legal advice may be barred from pursuing a legal malpractice claim based upon a defense of unclean hands. To prevail, however, the client’s conduct must be so obviously wrongful that, notwithstanding the negligent legal advice, the client could not have been confused about the illegality of its actions. Here, the debtor’s misconduct admitted in the trustee’s complaint – failing to comply with disclosure and licensing requirements – was “not so obviously wrongful” that the debtor must have known it to be unlawful.