Mealey's (May 29, 2019, 10:18 AM EDT) -- SAN FRANCISCO — In a May 24 unpublished holding, the Ninth Circuit U.S. Court of Appeals found that a federal judge in California erred in granting a summary judgment that an individual exercised common control over a business that incurred $1.4 million in liability when it withdrew from an employee benefit pension plan (Kevin Liebeck v. Trustees of the Southern California IBEW-NECA Pension Plan, No. 17-56188, 9th Cir., 2019 U.S. App. LEXIS 15592)....