P.W. and U.S. Postal Service, Detroit Vehicle Maintenance Facility (Board decision, August 6, 2026)
Postal employee's ankle injury denial upheld (ECAB 26-0473)
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ECAB final decision. The Board affirmed OWCP's January 26, 2026 denial of the left ankle injury claim. 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 motor vehicle operator reported falling in a worksite restroom and injuring her left ankle. OWCP accepted that the incident occurred but denied the claim. The Board found that her physician diagnosed an ankle fracture without explaining its cause. It affirmed the denial because the medical evidence did not connect the fracture to the accepted incident.
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 denial affirmed; causal relationship was not established.
- Key point: A diagnosis alone did not show that the accepted incident caused the ankle condition.
Full text (ECAB public release)
United States Department of Labor
Employees’ Compensation Appeals Board
________
)
P.W., Appellant
)
)
and ) Docket No. 26-0473
) Issued: August 6, 2026
U.S. POSTAL SERVICE, DETROIT VEHICLE
)
MAINTENANCE FACILITY, Detroit, MI,
)
Employer
)
__________ )
Appearances: Case Submitted on the Record
Appellant, pro se
Office of Solicitor, for the Director
DECISION AND ORDER
Before:
ALEC J. KOROMILAS, Chief Judge
JANICE B. ASKIN, Judge
VALERIE D. EVANS-HARRELL, Alternate Judge
JURISDICTION
On April 21, 2026 appellant filed a timely appeal from a January 26, 2026 merit decision of the Office of Workers’ Compensation Programs (OWCP). Pursuant to the Federal Employees’ Compensation Act1 (FECA) and 20 C.F.R. §§ 501.2(c) and 501.3, the Board has jurisdiction over the merits of this case.2
1
5 U.S.C. § 8101 et seq.
2
The Board notes that following the January 26, 2026 decision, OWCP received additional evidence. However, the Board’s Rules of Procedure provides: “The Board’s review of a case is limited to the evidence in the case record that was before OWCP at the time of its final decision. Evidence not before OWCP will not be considered by the Board for the first time on appeal.” 20 C.F.R. § 501.2(c)(1). Thus, the Board is precluded from reviewing this additional evidence for the first time on appeal. Id.
ISSUE
The issue is whether appellant has met her burden of proof to establish a left ankle condition causally related to the accepted September 29, 2025 employment incident.
FACTUAL HISTORY
On October 6, 2025 appellant, then a 63-year-old motor vehicle operator, filed a traumatic injury claim (Form CA-1) alleging that on September 29, 2025 she sustained a left ankle fracture when she fell in the restroom/locker room while in the performance of duty. She sought treatment at an urgent care facility that day, and in follow-up at a hospital. Appellant stopped work on September 30, 2025.
In a duty status report (Form CA-17) dated October 13, 2025, Dr. Andrew Mastay, a podiatrist, diagnosed left ankle fracture and provided work restrictions.
In a development letter dated October 22, 2025, OWCP informed appellant of the deficiencies of her claim. It advised her that medical evidence was needed for her claim to be accepted. OWCP afforded appellant 60 days to submit the requested evidence.
OWCP subsequently received an unsigned and undated note informing appellant that her left bimalleolar ankle open reduction internal fixation surgery was scheduled for October 17, 2025, to be performed by Dr. Mastay. It also received the first page of an unsigned September 29, 2025 report recounting appellant’s history of left ankle pain following a fall earlier that day, calendar entries noting appellant’s medical appointments in December 2025 and January 2026, and copies of co-payment authorizations.
In an October 3, 2025 note, Dr. Mastay noted appellant was treated on October 2, 2025 and remained off work pending surgery for a left ankle fracture.
On December 8, 2025 Dr. Mastay noted treatment for left ankle stiffness. He related that appellant fell at work in September 2025 and fractured her ankle in two places.
By decision dated January 26, 2026, OWCP denied appellant’s claim finding that she failed to establish a medical condition causally related to the accepted September 29, 2025 employment incident.
LEGAL PRECEDENT
An employee seeking benefits under FECA3 has the burden of proof to establish the essential elements of his or her claim, including that the individual is an employee of the United States within the meaning of FECA, that the claim was timely filed within the applicable time
3
Supra note 1.
2 limitation of FECA,4 that an injury was sustained in the performance of duty as alleged, and that any disability or medical condition for which compensation is claimed is causally related to the employment injury.5 These are the essential elements of each and every compensation claim, regardless of whether the claim is predicated upon a traumatic injury or an occupational disease.6
To determine whether a federal employee has sustained a traumatic injury in the performance of duty, it first must be determined whether fact of injury has been established. First, the employee must submit sufficient evidence to establish that he or she actually experienced the employment incident at the time and place, and in the manner alleged. Second, the employee must submit sufficient evidence to establish that the employment incident caused an injury.7
The medical evidence required to establish causal relationship between a claimed specific condition and an employment incident is rationalized medical opinion evidence. 8 The opinion of the physician must be based on a complete factual and medical background of the employee, must be one of reasonable medical certainty, and must be supported by medical rationale explaining the nature of the relationship between the diagnosed condition and specific employment incident identified by the employee.9
ANALYSIS
The Board finds that appellant has not met her burden of proof to establish a left ankle condition causally related to the accepted September 29, 2025 employment incident.
In support of her claim appellant submitted a Form CA-17, an October 3, 2025 note, and a December 8, 2025 report from Dr. Mastay, diagnosing left ankle fracture. However, Dr. Mastay did not offer an opinion regarding the cause of appellant’s diagnosed condition.10 The Board has held that medical evidence that does not offer an opinion regarding the cause of an employee’s
4
M.G., Docket No. 26-0089 (issued March 10, 2026); E.K., Docket No. 22-1130 (issued December 30, 2022);
F.H., Docket No. 18-0869 (issued January 29, 2020); J.P., Docket No. 19-0129 (issued April 26, 2019); Joe D. Cameron, 41 ECAB 153 (1989). 5 M.G., id.; S.H., Docket No. 22-0391 (issued June 29, 2022); L.C., Docket No. 19-1301 (issued January 29, 2020);
J.H., Docket No. 18-1637 (issued January 29, 2020); James E. Chadden, Sr., 40 ECAB 312 (1988). 6 M.G., id.; E.H., Docket No. 22-0401 (issued June 29, 2022); P.A., Docket No. 18-0559 (issued January 29, 2020);
K.M., Docket No. 15-1660 (issued September 16, 2016); Delores C. Ellyett, 41 ECAB 992 (1990). 7 M.G., id.; H.M., Docket No. 22-0343 (issued June 28, 2022); T.J., Docket No. 19-0461 (issued August 11, 2020);
K.L., Docket No. 18-1029 (issued January 9, 2019); John J. Carlone, 41 ECAB 354 (1989). 8 M.G., id.; S.M., Docket No. 22-0075 (issued May 6, 2022); S.S., Docket No. 19-0688 (issued January 24, 2020); A.M., Docket No. 18-1748 (issued April 24, 2019); Robert G. Morris, 48 ECAB 238 (1996). 9 M.G., id.; J.D., Docket No. 22-0935 (issued December 16, 2022); T.L., Docket No. 18-0778 (issued January 22, 2020); Y.S., Docket No. 18-0366 (issued January 22, 2020); Victor J. Woodhams, 41 ECAB 345, 352 (1989). 10 D.B., Docket No. 25-0919 (issued February 13, 2026); S.S., Docket no. 18-0081 (issued August 18, 2018).
3 condition is of no probative value on the issue of causal relationship.11 Therefore, this evidence is insufficient to establish appellant’s claim.
OWCP also received an undated note informing appellant of her scheduled surgery, and the first page of a September 29, 2025 report recounting an injury history of left ankle pain following a fall earlier that day. These documents were unsigned. OWCP also received calendar entries regarding medical appointments and copies of co-payment authorizations.12 The Board has long held that reports that are unsigned or bear an illegible signature lack proper identification and cannot be considered probative medical evidence because the author cannot be identified as a physician.13 Thus, this evidence is insufficient to establish appellant’s claim.
As the medical evidence of record is insufficient to establish a left ankle condition causally related to the accepted September 29, 2025 employment incident, the Board finds that appellant has not met his burden of proof.14
Appellant may submit new evidence or argument, together with a written request for reconsideration to OWCP within one year of this merit decision, pursuant to 5 U.S.C. § 8128(a) and 20 C.F.R. §§ 10.605 through 10.607.
CONCLUSION
The Board finds that appellant has not met her burden of proof to establish a left ankle condition causally related to the accepted September 29, 2025 employment incident.
11
See D.B., id.; L.B., Docket No. 18-0533 (issued August 27, 2018); D.K., Docket No. 17-1549 (issued July 6, 2018).
12
See C.W., Docket No. 21-0336 (issued September 1, 2021).
13
L.B., Docket No. 21-0353 (issued May 23, 2022); T.D., Docket No. 20-0835 (issued February 2, 2021); Merton J.
Sills, 39 ECAB 572, 575 (1988).
14
I.D., Docket No. 22-0848 (issued September 2, 2022); T.G., Docket No. 14-751 (issued October 20, 2014).
4
ORDER
IT IS HEREBY ORDERED THAT the January 26, 2026 decision of the Office of Workers’ Compensation Programs is affirmed.
Issued: August 6, 2026
Washington, DC
Alec J. Koromilas, Chief Judge
Employees’ Compensation Appeals Board
Janice B. Askin, Judge
Employees’ Compensation Appeals Board
Valerie D. Evans-Harrell, Alternate Judge Employees’ Compensation Appeals Board
5
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