CHICAGO - The owner of a company that withdrew from a multiemployer plan is personally liable for the company's withdrawal liability under the Employee Retirement Income Security Act, as amended by the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), because the owner owned and leased property to the company and because the owner performed independent-contractor work for a country club, the Seventh Circuit U.S. Court of Appeals ruled April 22 (Central States, Southeast and Southwest Areas Pension Fund, et al. v. Charles F. Nagy, No. 11-3055, 7th Cir.; 2013 U.S. App. LEXIS 7912).