J.D. and U.S. Postal Service, Kilmer Post Office (Board decision, April 16, 2026)

Board orders related emotional condition claims combined (ECAB 26-0101)

Decision type
Board decision
Docket
26-0101
Decided
April 16, 2026
Outcome
Remanded
Precedential status
Citable Board precedent
Checked against source
2026-10-06

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About this page: The plain-English summary and decision snapshot below were written by Ezel based on the official ECAB release. The full text is the agency's own release.
Read the official release (dol.gov)

ECAB remand decision. The Board set aside OWCP's July 2 and October 29, 2025 denials and remanded for combined review and a new decision; entitlement remains unresolved. A party may petition the Board for reconsideration within 30 days of issuance unless this order specifies another period, under 20 C.F.R. § 501.7(a). FECA compensation decisions are generally not subject to court review under 5 U.S.C. § 8128(b).

Plain-English summary

A postal worker reported emotional and physical conditions attributed to workplace events. OWCP denied the claim without combining a prior file involving a similar emotional condition. The Board directed OWCP to combine the files so it could consider all relevant evidence before deciding again.

Decision snapshot

  • Authority: Federal Employees' Compensation Act, 5 U.S.C. § 8101 et seq.; 20 C.F.R. §§ 501.2(c), 501.3.
  • Outcome: OWCP's denials were set aside and remanded.
  • Key point: Related emotional condition files needed combined review.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

_______
)
J.D., Appellant
)
)
and ) Docket No. 26-0101
) Issued: April 16, 2026
U.S. POSTAL SERVICE, KILMER POST
)
OFFICE, Edison, NJ, Employer
)
_________ )

Appearances: Case Submitted on the Record
Appellant, pro se
Office of Solicitor, for the Director

ORDER REMANDING CASE

Before:
ALEC J. KOROMILAS, Chief Judge
PATRICIA H. FITZGERALD, Deputy Chief Judge VALERIE D. EVANS-HARRELL, Alternate Judge

On November 8, 2025 appellant filed a timely appeal from July 2 and October 29, 2025 merit decisions of the Office of Workers’ Compensation Programs (OWCP). The Clerk of the Appellate Boards docketed the appeal as No. 26-0101.

On March 12, 2025 appellant, then a 48-year-old network specialist filed an occupational disease claim (Form CA-2) alleging that he developed mental health and physical disabilities due to factors of his federal employment.1 He asserted that E.D., his manager, yelled, harassed, abused, and exasperated him causing a hostile work environment. Appellant noted that he first became aware of his claimed condition on February 23, 2025 and realized its relation to his federal employment on March 12, 2025. He stopped work on March 2, 2025. On the reverse side of the claim form, the employing establishment controverted the claim.

Appellant submitted evidence in support of his claim.

1
OWCP assigned the present claim OWCP File No. xxxxxx064. Appellant has a prior traumatic injury claim (Form CA-1) before OWCP. Under OWCP File No. xxxxxx968, he alleged that he sustained mental illness due extreme stress from work on October 27, 2024. Appellant’s claims have not been administratively combined by OWCP.
By decision dated July 2, 2025, OWCP denied appellant’s occupational disease claim, finding that he had not established a compensable employment factor. It concluded, therefore, that the requirements had not been met to establish an injury under FECA.

On July 27, 2025 appellant requested reconsideration and submitted additional evidence.
By decision dated October 29, 2025, OWCP denied modification.

The Board, having duly considered this matter, finds that the case is not in posture for decision.

OWCP’s procedures provide that cases should be administratively combined when correct adjudication depends on frequent cross-referencing between files, including when similar conditions are claimed in such cases.2 This allows OWCP to consider all relevant claim files in developing a given claim.3 Appellant’s claim under OWCP File No. xxxxxx968 also involved an emotional/stress-related condition. It should, therefore, be administratively combined with the present claim for a full and fair adjudication.4 This will allow OWCP to consider all relevant evidence in developing appellant’s claim.5

The case shall, therefore, be remanded for OWCP to administratively combine OWCP File No. xxxxxx968 with the present claim, OWCP File No. xxxxxx064. Following this and other such further development as deemed necessary, OWCP shall issue a de novo decision. Accordingly,

2
Federal (FECA) Procedure Manual, Part 2 -- Claims, File Maintenance and Management, Chapter 2.400.8c (February 2000).
3
Id.
4
See Order Remanding Case, Docket Nos. 25-0118; 25-0119 (issued December 10, 2024). Order Remanding Case, S.B., Docket No. 25-0797 (issued November 26, 2025); Order Remanding Case, M.K., Docket No. 25-0184 (issued February 18, 2025); Order Remanding Case, J.L., Docket No. 24-0785 (issued November 1, 2024); Order Remanding Case, M.T., Docket No. 24-0753 (issued September 23, 2024); Order Remanding Case, K.W., Docket No. 22-1258 (issued March 14, 2023). 5 Id. See also K.G., Docket No. 21-0068 (issued July 29, 2022); D.J., Docket No. 20-0997 (issued November 20, 2020); S.D., Docket No. 19-0590 (issued August 28, 2020).

2
IT IS HEREBY ORDERED THAT the July 2 and October 29, 2025 decisions of the Office of Workers’ Compensation Programs are set aside, and the case is remanded for further proceedings consistent with this order of the Board.

Issued: April 16, 2026
Washington, DC

Alec J. Koromilas, Chief Judge
Employees’ Compensation Appeals Board

Patricia H. Fitzgerald, Deputy Chief Judge Employees’ Compensation Appeals Board

Valerie D. Evans-Harrell, Alternate Judge Employees’ Compensation Appeals Board

3

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