The report is that one previously Pandalyzed site is now enjoying skyrocketed rankings. Let's not jump to conclusions and hypothetical situations - that's not solid analysis, especially when it comes to something as wildly variable as Panda.
I know of one site that I keep expecting to get nailed at any time, but it just keeps sailing. Another site recovered rather nicely after just a bit of technical clean-up. And a third has been plugging away at many improvements but still suffers from a severe February Panda hit. So accurate generalizations are hard to come by and not a wise step to take.