Generally, an order denying summary judgment is not reviewable on an appeal from a judgment entered after trial. Ortiz v. Jordan (2011) 562 U.S. 180, 184-185. However, at least in the Ninth Circuit, the Court of Appeals may review an order denying summary judgment on a post-trial appeal if the denial was based on a purely legal issue, such as federal preemption of state law. Banuelos v. Constr. Laborers’ Tr. Funds for S. Cal. (9th Cir. 2004) 382 F.3d 897, 902.