Mealey's (November 26, 2019, 11:07 AM EST) -- BOSTON — The First Circuit U.S. Court of Appeals on Nov. 22 reversed a district court’s ruling that two limited partnership private equity funds were under common control of a bankrupt subsidiary and, therefore, were liable to pay that firm’s pro rata share of unfunded vested benefits, totaling $4.5 million, which it owed to a multiemployer pension fund from which it withdrew because the factors in a multifactored partnership test were not met (Sun Capital Partners III LP, et al. v. New England Teamsters and Trucking Industry Pension Fund, Nos. 16-1376, 19-1002, 1st Cir., 2019 U.S. App. LEXIS 34983)....