Federal Agency Decisions
Federal workers' compensation appeals from the Department of Labor's Employees' Compensation Appeals Board (ECAB), federal-sector labor-relations cases from the Federal Labor Relations Authority (FLRA), mine-safety cases from the Federal Mine Safety and Health Review Commission (FMSHRC), workplace-safety cases from the Occupational Safety and Health Review Commission (OSHRC), Longshore Act and Black Lung Benefits Act appeals from the Department of Labor's Benefits Review Board (BRB), precedent decisions of the Board of Immigration Appeals (BIA), environmental permit and penalty appeals from the EPA's Environmental Appeals Board (EAB), and whistleblower and other labor appeals from the Department of Labor's Administrative Review Board (ARB), each with a plain-English summary, the law it cites, and whether it counts as precedent. More agencies are coming.
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Cieslicki v. Soo Line Railroad Co. dba Canadian Pacific
Self-reported impairment may be protected
Soo Line terminated Andre Cieslicki after he said he could not report for railroad duty because he had consumed alcohol with dinner and believed working would violate federal alcohol-safety rules. The ALJ dismissed because it viewed a worker's self-reported off-duty condition as outside the Federal…
Berg v. S&H Express
Employer lacked knowledge of protected driving refusals
Truck driver Susan Marie Berg stopped work early because of tooth pain and then missed two days while taking prescription pain medication that made her drowsy. The ALJ treated her decisions not to drive as protected but found that she had not told S&H Express they were based on safety concerns or…
S.B. and Department of Homeland Security, Federal Air Marshal Service, Egg Harbor Township, NJ
Cervical injury claim denied for inaccurate medical history
S.B., a federal air marshal, reported neck symptoms after prolonged awkward sitting at work. A physician linked his cervical diagnoses to stowing items overhead, a different mechanism than the incident OWCP accepted. The Board found that this inaccurate history and other deficiencies left the…
J.E. and U.S. Postal Service, Post Office, Ogden, UT
Acute kidney diagnosis established; causation returned to OWCP
J.E., a city carrier assistant, reported heat-related illness during a hot walking route. A physician diagnosed acute kidney injury and related laboratory abnormalities. The Board found that a diagnosed condition was established in connection with the accepted incident, correcting OWCP’s basis for…
V.B. and U.S. Postal Service, Processing & Distribution Center, San Jose, CA
Unproven retirement overlap overpayment reversed
V.B. elected Office of Personnel Management retirement benefits while receiving FECA wage-loss compensation. OWCP asserted a $1,946.03 overpayment for December 18, 2018 through January 5, 2019. The Board found no proof that he actually received retirement benefits during that period. An election…
W.F. and Department of Homeland Security, Transportation Security Administration, Norfolk, VA
Late written-record review request denied
W.F., a transportation security screener, sought review by an OWCP hearing representative after a December 20, 2018 decision. Her request was postmarked June 17, 2019, beyond the 30-day period for a hearing or written-record review as of right. The Board upheld OWCP’s denial of that review request.
W.C. and U.S. Postal Service, Woodstock Post Office, Woodstock, IL
Wage-loss and right-knee expansion denials affirmed
W.C., a postal employee, sought wage-loss compensation for December 2018 through February 2019 and expansion of an accepted 2016 injury claim to include another right knee condition. The Board found insufficient proof that the accepted injury caused disability during the claimed periods or caused…
D.V. and U.S. Postal Service, Philadelphia Network Distribution Center Annex, Philadelphia, PA
Right-wrist injury denial affirmed
D.V., a casual mail handler, reported right wrist pain after a box slipped while he was lifting it. The Board accepted the November 29, 2018 incident but found that the submitted medical evidence did not adequately establish that it caused a right wrist condition. It upheld the denial.
L.P. and U.S. Postal Service, Post Office, Merrifield, VA
Back injury claim returned for medical development
L.P., a rural carrier with a prior spinal fusion, felt a sudden back injury while bending to deliver a package. Her physician described a broken spinal rod and explained how the work incident could have caused it. The Board found that this reasoned opinion warranted further development of the…
Outfront Media, Inc.
Three billboard fall-protection items vacated
An OSHA compliance officer observed four Outfront Media employees working more than four feet above ground on a billboard without fall protection. OSHA cited fall protection, fall-hazard training, and workplace hazard-assessment requirements, with a proposed grouped penalty of $12,675. The judge…
International Brotherhood of Electrical Workers, Local 1002 and United States Department of Energy, Southwestern Power Administration, Tulsa, Oklahoma
IBEW Local 1002 and Southwestern Power Administration (FLRA 0-NG-3442): Authority dismisses late negotiability petition
IBEW Local 1002 sought review of two pay proposals that the Southwestern Power Administration had previously declared nonnegotiable. The union had withdrawn an earlier petition covering the proposals without reserving a right to refile, then made only minor modifications before submitting them…
Tucker v. CSX Transportation, Inc.
Injury report came after discharge decision
CSX removed conductor Phillip Tucker from service after he marked off for a doctor's appointment that he did not have, then terminated him under its dishonesty rule. Tucker alleged that he had injured his knee at work and that the discharge retaliated against his injury report and refusal to work…
N.M. and Department of Homeland Security, Transportation Security Administration, Federal Air Marshal Service, Orlando, FL
Existing left-leg schedule award affirmed
N.M., a federal air marshal, sought more than the existing three percent left lower extremity impairment award after an accepted knee injury. A physician supplied a higher rating using range of motion because it yielded a larger result. The Board found that this method did not comply with the…
C.E. and U.S. Postal Service, Crooked Hill Post Office, Harrisburg, PA
Dermatitis wage-loss claim returned for factual findings
C.E., a postal mail processing clerk, sought wage-loss compensation for intermittent periods after OWCP accepted bilateral hand dermatitis. OWCP denied the claim on the theory that light duty was available, but did not establish what the job required, whether gloves were necessary, or whether a…
K.A. and U.S. Postal Service, Post Office, Nashville, TN
Disability and reconsideration denials affirmed
K.A., a postal mail processor, claimed total disability during periods from November 2018 through February 2019 after an accepted injury. The Board found that the evidence did not establish the claimed disability from the accepted condition. It also upheld OWCP’s refusal to reopen an earlier merits…
National Association of Government Employees and United States Department of Defense, Defense Commissary Agency
NAGE and Defense Commissary Agency (FLRA 0-AR-5496): Authority upholds dismissal of late suspension grievance
The Defense Commissary Agency notified an employee and the union of its suspension decision, and the union filed a grievance more than fourteen days later. An arbitrator found that the negotiated grievance procedure measured the filing period from notice of the decision, not from the suspension's…
Secretary of Labor v. Peabody Midwest Mining, LLC
Refuge-chamber S&S finding reversed
Peabody violated its emergency response plan by placing one refuge chamber in the direct line of sight of the working face. The Commission majority held that the violation was not significant and substantial because the properly located chamber could hold the 15-miner production crew, while more…
K.F. and U.S. Postal Service, Post Office, Andover, KS
Cervical claim returned for impartial medical opinion
K.F., a postal associate, attributed neck conditions to repetitive lifting and other work duties. Her treating physicians and an OWCP referral physician gave conflicting opinions about whether work aggravated an existing cervical condition. The Board found a medical conflict requiring an impartial…
A.K. and U.S. Postal Service, Bloomington Post Office, Bloomington, IL
Injury denial affirmed; timely reconsideration returned
A.K., a postal employee, sought compensation for a lumbar condition attributed to work duties. The Board found that the medical evidence did not establish causation and affirmed the June 2019 merits denial. OWCP nevertheless treated her reconsideration request, received eight days later, as…
J.B. and Department of Homeland Security, Transportation Security Administration, Sacramento, CA
Overpayment and recovery deduction affirmed
J.B. received FECA wage-loss compensation and age-related Social Security retirement benefits without the required offset. The Board upheld a $7,577.11 overpayment for November 1, 2013 through February 2, 2019. It found her without fault but upheld OWCP’s refusal to waive recovery and its deduction…
B.C. and U.S. Postal Service, Medway Post Office, Medway, MA
Overpayment and recovery terms affirmed
B.C. received FECA compensation while also receiving age-related Social Security retirement benefits attributable to federal service. The Board upheld a $50,438.34 overpayment for March 1, 2014 through May 26, 2018. Although she was without fault, it also affirmed denial of waiver and the periodic…
D.M. and Social Security Administration, Richmond, CA
Workplace fall returned for fact-of-injury review
D.M., a Social Security Administration claims representative, lost consciousness and fell while serving a customer at work. OWCP treated the fall as solely idiopathic, or due to a personal condition. The Board found that D.M. struck a supporting surface at work as he fell, making the fall covered…
M.H. and Department of Veterans Affairs, Veterans Health Administration, Hines, IL
Lumbar claim expansion returned for medical development
M.H., a VA employee, sought expansion of an accepted 2016 injury claim to include a lumbar condition and sought wage-loss compensation. Her physician described a possible work-related aggravation of existing lumbar disease. The Board found that his opinion did not yet prove entitlement but…
United States Department of the Treasury, Internal Revenue Service and National Treasury Employees Union, Chapter 97
Internal Revenue Service and NTEU Chapter 97 (FLRA 0-AR-5513): Authority bars classification grievance
NTEU Chapter 97 claimed that GS-4 Internal Revenue Service employees processed amended tax returns at the GS-6 level and deserved retroactive temporary promotions. An arbitrator granted relief under the parties' agreement after finding that amended-return work was GS-6 work. The Authority held that…
K.T. and Department of Veterans Affairs, San Diego Healthcare System, San Diego, CA
Reconsideration denial returned for review of medical letter
K.T., a VA health technician, sought reconsideration of a left knee injury denial. He submitted a physician’s letter describing a preexisting knee condition aggravated by the work incident. The Board found that OWCP had failed to address this relevant evidence when refusing merit review. It…
R.M. and U.S. Postal Service, Post Office, Alpharetta, GA
Overpayment and recovery terms affirmed
R.M. received FECA benefits and age-related Social Security retirement benefits without the required offset. The Board upheld a $41,177.89 overpayment for May 20, 2011 through March 30, 2019. Although he was without fault, it affirmed denial of waiver and the periodic recovery amount.
J.W. and U.S. Postal Service, Twenty-Second Street Station, Chicago, IL
Bilateral wrist claim returned for medical development
J.W., a mail carrier, attributed bilateral wrist tendinitis to repetitive casing and other mail duties. A physician described the risk factors in those duties and how they could produce tendon inflammation. The Board found the opinion sufficient to require further development, though the existing…
A.H. and Department of the Navy, Naval Facilities, Pearl City, HI
Adjustment-disorder denial affirmed; disc claim returned
A.H., a Navy employee, sought expansion of an accepted injury claim to include adjustment disorder and a herniated disc. The Board found the record did not establish the emotional condition. A physician’s account of how lifting a heavy locker could have caused a disc herniation was insufficient to…
Hannah Covarrubias v. Global Linguist Solutions, LLC
Covarrubias v. Global Linguist Solutions (BRB 19-0559): dismissal under earlier settlement upheld
Hannah Covarrubias worked as a linguist in Iraq and filed claims for psychological injuries she attributed to workplace harassment. She later settled one claim for $228,000, and a judge dismissed a revived 2008 claim on summary decision. The Board held that the settlement covered injuries during…
Vivian Bradley v. Miller Brothers Coal LLC
Bradley v. Miller Brothers Coal (BRB 19-0352 and 19-0357 BLA): miner and survivor awards upheld
Vivian Bradley pursued her late husband's black lung claim and her own survivor claim. The judge found Dwight Bradley had more than fifteen years of surface mine work with regular coal dust exposure and was totally disabled, triggering the statutory presumption. Miller Brothers Coal argued that…
Allen T. Mitchell v. Island Creek Kentucky Mining
Mitchell v. Island Creek Kentucky Mining (BRB 19-0313 BLA): disease finding returned for review
Allen Mitchell appealed the denial of his second subsequent claim for black lung benefits. The Board upheld the finding of 10.33 years of mine work, leaving him short of the fifteen-year presumption. It vacated the finding against clinical pneumoconiosis because the judge did not explain why one…
Howard Hays v. Begwell Trucking, Incorporated
Hays v. Begwell Trucking (BRB 19-0301 BLA): black lung benefits denial upheld
Howard Hays sought black lung benefits after twenty-six years of coal mine work. The judge found that Hays had not proved a totally disabling respiratory impairment, which was necessary both for entitlement and for the fifteen-year presumption. On Hays's appeal without a lawyer, the Board upheld…
Charlotte A. Gregory v. Barnes & Tucker Company
Gregory v. Barnes & Tucker (BRB 19-0290 BLA): survivor's benefits award upheld
Charlotte Gregory received survivor's benefits after a judge found that her late husband had complicated pneumoconiosis caused by coal mine work. Barnes & Tucker challenged the judge's interpretation of lung lesions measured in autopsy evidence. The Board held that the autopsy measurements and a…
Danny L. Hall v. Del Rio, Incorporated
Hall v. Del Rio (BRB 19-0282 BLA): claim returned for a complete pulmonary evaluation
Danny Hall sought black lung benefits after a judge found that he had at least fifteen years of underground mine work but had not proved total respiratory disability. The Board agreed with the Director that Hall had not received the complete pulmonary evaluation required by the Act. The examining…
Donald Ray Maggard v. Enterprise Mining Company, Incorporated
Maggard v. Enterprise Mining Company (BRB 19-0232 BLA): black lung benefits upheld
Donald Ray Maggard sought black lung benefits after working at least thirty-five years underground for coal mines. Enterprise Mining challenged the judge's appointment and the finding that Maggard was totally disabled. The Board rejected the appointment challenge because the judge issued only a…
Cheri Lynn Webb, executrix of the estate of William E. Vincent, v. Peabody Coal Company and Peabody Energy Corporation
Webb v. Peabody Coal Company (BRB 19-0122 BLA): black lung benefits and carrier liability upheld
Cheri Lynn Webb pursued the black lung claim of William E. Vincent's estate. Peabody Coal and Peabody Energy challenged the benefits award and Peabody Energy's liability as carrier. The Board held that they forfeited their objection to the district director's appointment by first raising it on…
C.W. and U.S. Postal Service, Processing & Distribution Center, Charleston, WV
Back diagnosis established; causation returned to OWCP
C.W., a postal employee, claimed a lower back condition after a work incident. A chiropractor diagnosed spinal subluxation using an x-ray report, making that opinion competent medical evidence under FECA for the relevant purpose. The Board found valid diagnoses in the record and returned the case…
M.N. and Department of the Army, Tank Automotive & Armaments Command, Red River Army Depot, Texarkana, TX
Benefit suspension for obstructed examination affirmed
M.N., an Army depot employee, was scheduled for a medical appointment related to his compensation claim. OWCP found that his conduct obstructed the examination. The Board held that OWCP properly suspended his compensation under the statutory examination rule and affirmed the decision.
J.K. and Department of Veterans Affairs, Veterans Administration Medical Center, Kansas City, MO
Workplace bite established; medical issue returned
J.K., a VA medical support assistant, reported a spider bite on her ankle while working. The employer’s acknowledgment, a health unit report, and medical histories supported that the October 24, 2018 bite occurred at work. The Board found the incident established and returned the claim for…
R.W. and Department of Defense, Defense Commissary Agency, Memphis, TN
Slip-and-fall injury claim denied for insufficient causation
R.W., a commissary meat cutter, slipped on water at work and reported arm and back symptoms. The Board accepted the October 14, 2017 fall but found that the medical opinions did not adequately explain how it caused or aggravated the claimed conditions. It affirmed the denial.
L.M. and Department of Defense, Defense Finance & Accounting Services, Indianapolis, IN
Back and foot injury claim denied
L.M., a military pay technician, reported that a desk struck his foot and strained his back while he moved furniture at work. The Board accepted the June 8, 2018 incident but found that the medical reports did not adequately establish a causal link to a diagnosed injury. It upheld OWCP’s denial.
K.C. and U.S. Postal Service, Post Office, Kewaunee, WI
Foot-injury claim returned for impartial medical opinion
K.C., a rural carrier associate, slipped on ice at work and later underwent treatment for a diabetic left foot infection. His treating surgeon and an OWCP referral physician gave conflicting, reasoned opinions about whether the accepted December 2016 incident contributed to the condition. The Board…
United States Department of Veterans Affairs, John J. Pershing VA Medical Center (Agency) and American Federation of Government Employees, Local 2328 (Union)
VA John J. Pershing Medical Center and AFGE Local 2328 (FLRA 0-AR-5491): Nursing hazard pay award partly set aside
The union sought hazard pay for registered nurses, licensed practical nurses, and support staff who handled medical waste at VA outpatient facilities. The arbitrator held that the registered nurses' compensation claim could not be arbitrated and awarded hazard pay to the other employees. The…
Watts v. Perdue Farms, Inc.
Food-safety coverage ruling reconsidered
Contract chicken grower Craig Watts alleged that Perdue Farms required extra biosecurity training after he publicized concerns about conditions on his farm. The Board had affirmed dismissal on the ground that poultry operations were exempt from the federal food law supporting his retaliation claim…
K.V. and U.S. Postal Service, Post Office, Fairbanks, AK
Compensation forfeiture following fraud plea affirmed
K.V., a postal customer service supervisor, had received benefits for an accepted injury. He pleaded guilty to federal wire fraud charges on May 18, 2018. The Board found that the statutory forfeiture provision applied and upheld OWCP’s termination of compensation from that date.
G.M. and Department of the Navy, Space & Naval Warfare Systems Center, San Diego, CA
Right-leg impairment rating returned for clarification
G.M., a Navy procurement officer, sought more than the existing 13 percent right lower extremity award after an accepted ankle injury. Her physician used an outdated edition of the impairment guide. OWCP’s medical adviser used the correct edition but did not explain sensory findings and grade…
C.W. and U.S. Postal Service, Waverly Station, Baltimore, MD
Ankle injury claim returned after wrong development letter
C.W., a city carrier associate, reported breaking her ankle while delivering mail. OWCP sent a development letter about an unrelated assault claim and later denied her ankle claim for failure to answer that letter. The Board found that she had never received case-specific guidance about the…
C.C. and Department of Justice, Federal Bureau of Prisons, Federal Correctional Institution, Miami, FL
Timely reconsideration request still failed to reopen claim
C.C., a prison cook supervisor, sought reconsideration of a prior decision on an accepted injury. His one-year filing deadline fell on a Saturday, so a request received the following Monday was timely. The Board nevertheless found that his submission did not satisfy any ground for reopening merit…
R.S. and U.S. Postal Service, Post Office, Santa Maria, CA
Intermittent wage-loss claim returned for correct findings
R.S., a postal carrier, claimed intermittent wage-loss compensation for March 6 through April 28, 2017. OWCP later characterized its earlier denial as a termination of ongoing wage-loss compensation, although it had denied an intermittent claim and had also authorized payment for that period. The…
Daniel Hill v. Northrop Grumman
Hill v. Northrop Grumman (BRB 20-0064): occupational dust claim returned for review
Daniel Hill sought Defense Base Act benefits for interstitial lung disease after working for Northrop Grumman in Afghanistan. He reported exposure to dust and burn pit fumes, but the judge denied the claim after crediting a doctor's opinion that the disease was unrelated to work. The Board upheld…
Robert M. Combs v. Cumberland River Coal Company
Combs v. Cumberland River Coal Company (BRB 19-0360 BLA): new hearing ordered after appointment challenge
Robert Combs received black lung benefits after a judge found that his coal mine work and respiratory disability triggered the fifteen-year presumption. Cumberland River Coal challenged the judge's appointment. The judge had held a hearing, admitted evidence, and heard testimony before the…
Dickie K. Ratliff v. Hawkins Coal Company
Ratliff v. Hawkins Coal Company (BRB 19-0350 BLA): black lung benefits upheld
Dickie Ratliff received black lung benefits after a judge found that at least fifteen years of qualifying coal mine work and a disabling respiratory impairment triggered the fifteen-year presumption. Hawkins Coal challenged the revived presumption and argued that its medical evidence rebutted it…
Henry D. Stevenson v. Consolidation Coal Company
Stevenson v. Consolidation Coal Company (BRB 19-0275 BLA): black lung benefits upheld
Henry Stevenson won black lung benefits after at least thirty-three years of underground coal mine work. Consolidation Coal challenged the judge's appointment, the validity of the fifteen-year presumption, and the finding that it failed to rebut the presumption. The Board held that the employer…
Bonnie S. Keen v. Island Creek Kentucky Mining
Keen v. Island Creek Kentucky Mining (BRB 19-0274 BLA): survivor benefits upheld
Bonnie Keen sought survivor benefits after her husband, Jimmie Keen, died. The judge found he had twenty years of qualifying coal mine work and was totally disabled by a respiratory impairment before his death, triggering the fifteen-year presumption that pneumoconiosis caused his death. The Board…
Gary W. Cook v. Wellmore Energy Company, LLC
Cook v. Wellmore Energy (BRB 19-0261 BLA): benefits upheld, responsible operator issue returned
Gary Cook won black lung benefits after the employer conceded that he had complicated pneumoconiosis. Wellmore Energy did not challenge his entitlement, but argued that an x-ray reading showed he already had the disease before working for it. The judge excluded that reading when deciding which…
Dale L. Allen v. Island Creek Kentucky Mining Company and Island Creek Coal Company
Allen v. Island Creek Kentucky Mining (BRB 19-0201 BLA): benefits award sent back for disability findings
Dale Allen sought black lung benefits after a judge found he had legal pneumoconiosis and a totally disabling respiratory impairment caused by it. The Board upheld the disease finding because a physician reasonably attributed Allen's lung disease in part to coal mine dust. The judge had credited…
Trena Taylor, on behalf of and survivor of Rush Taylor, v. Hawkins Coal Company
Taylor v. Hawkins Coal Company (BRB 19-0128 and 19-0129 BLA): miner and survivor claims returned for review
Trena Taylor sought to reopen the denied black lung claims of her late husband, Rush Taylor, and herself as his survivor. The judge found that the employer had rebutted the fifteen-year presumption of pneumoconiosis and again denied both claims. The Board found that the judge did not adequately…
Hurley C. Collins v. Clinchfield Coal Company
Collins v. Clinchfield Coal Company (BRB 19-0079 BLA): reconsideration and en banc review denied
Clinchfield Coal Company asked the Board to reconsider its February 2020 decision in Hurley Collins's black lung benefits case and suggested review by the full Board. After considering the employer's arguments and its earlier ruling, no Board member voted for reconsideration. The Board denied the…
Johnny P. Cline v. Lake Energy, Incorporated and West Virginia Coal Workers' Pneumoconiosis Fund
Cline v. Lake Energy (BRB 18-0610 and 19-0068 BLO): overpayment waiver upheld, future offset restored
Johnny Cline received federal black lung benefits while also receiving state workers' compensation benefits for disability due in part to pneumoconiosis. The district director found a $15,510.80 overpayment because interim federal benefits had not been reduced for the state payments. A judge waived…
Mary Louise Brothers v. Pittsburg & Midway Coal Mining Company
Brothers v. Pittsburg & Midway Coal Mining Company (BRB 18-0528 BLA): reconsideration denied
Mary Louise Brothers asked the Board to reconsider its October 2019 decision in her black lung case. No Board member voted to vacate or modify that decision, so the Board denied reconsideration. This order does not describe what the earlier decision held.
What these documents are
- The agencies: Federal workers' compensation appeals from the Department of Labor's Employees' Compensation Appeals Board (ECAB), federal-sector labor-relations cases from the Federal Labor Relations Authority (FLRA), mine-safety cases from the Federal Mine Safety and Health Review Commission (FMSHRC), workplace-safety cases from the Occupational Safety and Health Review Commission (OSHRC), Longshore Act and Black Lung Benefits Act appeals from the Department of Labor's Benefits Review Board (BRB), precedent decisions of the Board of Immigration Appeals (BIA), environmental permit and penalty appeals from the EPA's Environmental Appeals Board (EAB), and whistleblower and other labor appeals from the Department of Labor's Administrative Review Board (ARB). Each decision page names its agency.
- Commission, Board and Authority decisions: Rulings by the agency's highest review level (the Commission at OSHRC and FMSHRC, the Authority at FLRA, the Board of Immigration Appeals, the Administrative Review Board at Labor, and the Environmental Appeals Board at EPA). These are citable as precedent, though a decision may have been appealed to a U.S. Court of Appeals after issuance.
- ALJ decisions: Rulings by the agency's Administrative Law Judges after a hearing. When no Commissioner directs review, an ALJ decision becomes a final order that binds the parties in that case but is not binding precedent: under 29 U.S.C. § 661(j) at OSHRC, and after the 40-day window of 30 U.S.C. § 823(d)(1) at FMSHRC.
- Why finality matters: Every page here says which kind of decision you are reading, so you know whether it is precedent you can cite or a final order that only shows how one judge ruled on one set of facts.
- Where they come from: Every page links the official public release from the deciding agency, and the full text on the page is that release. The plain-English summaries are written by Ezel.