K.T. and U.S. Postal Service, Detroit Post Office (Board decision, August 13, 2026)
Postal carrier's foot condition claim denied for lack of causation evidence (ECAB 26-0499)
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ECAB final decision. The Board affirmed OWCP's denial of the occupational disease 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). Under 5 U.S.C. § 8128(b), FECA compensation decisions are generally not subject to court review.
Plain-English summary
A Detroit postal carrier claimed that years of walking on concrete caused a right foot condition. OWCP denied her occupational disease claim. The Board found that the submitted medical evidence did not explain whether her work duties caused or aggravated the condition. It affirmed the denial because her own account of the work factors could not supply the required medical causation opinion.
Decision snapshot
- Authority: Federal Employees' Compensation Act, 5 U.S.C. § 8101 et seq.; 20 C.F.R. §§ 501.2(c), 501.3.
- Outcome: Occupational disease claim denial affirmed.
- Key point: A diagnosis and description of work exposure did not establish a medical connection between them.
Full text (ECAB public release)
United States Department of Labor
Employees’ Compensation Appeals Board
________
)
K.T., Appellant
)
)
and ) Docket No. 26-0499
) Issued: August 13, 2026
U.S. POSTAL SERVICE, DETROIT POST
)
OFFICE, 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
PATRICIA H. FITZGERALD, Deputy Chief Judge VALERIE D. EVANS-HARRELL, Alternate Judge
JURISDICTION
On May 5, 2026 appellant filed a timely appeal from a December 22, 2025 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.
ISSUE
The issue is whether appellant has met her burden of proof to establish a right foot condition causally related to the accepted factors of her federal employment.
FACTUAL HISTORY
On October 2, 2025 appellant, then a 46-year-old city carrier, filed an occupational disease claim (Form CA-2) alleging that she developed a right foot hallux limitus due to factors of her
1
5 U.S.C. § 8101 et seq. federal employment, including walking on concrete. She noted that she first became aware of this condition on July 17, 2025, and realized its relation to her federal employment on October 2, 2025.
In a development letter dated October 16, 2025, OWCP informed appellant of the deficiencies of her claim. It advised her of the type of factual and medical evidence needed and provided a questionnaire for her completion. OWCP afforded appellant 60 days to respond. In a letter of the same date, it requested that the employing establishment provide information regarding her claim, including comments from a knowledgeable supervisor. OWCP afforded the employing establishment 30 days to provide the requested information.
In a narrative statement dated November 12, 2025, appellant indicated that she had a protruding bone on the top of her first toe on her right foot. She attributed this condition to walking on concrete for 8 to 10 hours per day, five to six days per week over the course of 10 years. Appellant explained that she experienced constant pain in her foot while walking and shooting and tingling pain after walking. She further related that she had received a diagnosis from a podiatrist after attempting to relieve her symptoms by adjusting her footwear, using orthotic inserts and padding, and undergoing injections. Appellant also submitted a completed development questionnaire, wherein she further attributed her condition to walking on concrete for 10 years.
In a December 7, 2025 report, Dr. Tameka Parham Taylor, a Board-certified podiatrist, reviewed appellant’s medical records and summarized her medical treatment. She noted appellant’s physical examination findings and diagnosed hallux limitus/rigidus, post-traumatic right foot osteoarthritis, and right foot pain. Dr. Taylor also noted appellant’s statements that her foot pain was aggravated by her job as city carrier.
By decision dated December 22, 2025, OWCP denied appellant’s claim, finding that the medical evidence of record was insufficient to establish a right foot condition causally related to the accepted factors of her federal employment.
LEGAL PRECEDENT
An employee seeking benefits under FECA2 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 limitation of FECA,3 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
2
Id.
3
See J.P., Docket No. 25-0889 (issued December 5, 2025); B.E., Docket No. 24-0614 (issued July 12, 2024);
S.F., Docket No. 23-0264 (issued July 5, 2023); F.H., Docket No. 18-0869 (issued January 29, 2020); Joe D. Cameron, 41 ECAB 153 (1989).
2 employment injury.4 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.5
To establish that an injury was sustained in the performance of duty in an occupational disease claim, a claimant must submit: (1) a factual statement identifying employment factors alleged to have caused or contributed to the presence or occurrence of the disease or condition; (2) medical evidence establishing the presence or existence of the disease or condition for which compensation is claimed; and (3) medical evidence establishing that the diagnosed condition is casually related to the identified employment factors.6
Causal relationship is a medical question that requires rationalized medical opinion evidence to resolve the issue.7 The opinion of the physician must be based upon a complete factual and medical background, 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 the specific employment factors.8
ANALYSIS
The Board finds that appellant has not met her burden of proof to establish a right foot condition causally related to the accepted factors of her federal employment.
In a report dated December 7, 2025, Dr. Taylor noted appellant’s diagnoses of right foot hallux limitus/rigidus, post-traumatic right foot osteoarthritis, and right foot pain. However, she did not provide an opinion regarding the cause of appellant’s right foot conditions. The Board has held that medical evidence that does not offer an opinion regarding the cause of an employee’s condition is of no probative value on the issue of causal relationship.9 Therefore, this evidence is insufficient to establish appellant’s claim.
As the medical evidence of record is insufficient to establish that appellant sustained a right foot condition causally related to the accepted factors of her federal employment, the Board finds that she has not met her burden of proof.
4
J.P., id.; B.E., id.; 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). 5 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).
6
T.W., Docket No. 20-0767 (issued January 13, 2021); L.D., Docket No. 19-1301 (issued January 29, 2020);
S.C., Docket No. 18-1242 (issued March 13, 2019).
7
I.J., Docket No. 19-1343 (issued February 26, 2020); T.H., 59 ECAB 388 (2008); Robert G. Morris, 48 ECAB 238 (1996).
8
J.P., supra note 3; B.E., supra note 3; D.C., Docket No. 19-1093 (issued June 25, 2020); see Victor J. Woodhams, 41 ECAB 345 (1989). 9 See K.A., Docket No. 26-0031 (issued February 26, 2026); B.B., Docket No. 25-0661 (issued September 9, 2025); L.B., Docket No. 18-0533 (issued August 27, 2018); D.K., Docket No. 17-1549 (issued July 6, 2018).
3
Appellant may submit new evidence or argument with a written request for reconsideration to OWCP within one year of this merit decision, pursuant to 5 U.S.C. § 8128 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 right foot condition causally related to the accepted factors of her federal employment.
ORDER
IT IS HEREBY ORDERED THAT the December 22, 2025 decision of the Office of Workers’ Compensation Programs is affirmed.
Issued: August 13, 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
4
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