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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Jake's Fireworks, Inc.
Fireworks storage and hazard-control violations affirmed
Jake's Fireworks employees were clearing old and damaged consumer fireworks from storage containers at a former Kansas facility when a fire broke out. Both employees were badly burned, and one later died. The judge found that damaged fireworks, exposed pyrotechnic material, combustible debris, and…
Social Security Administration (Agency) and American Federation of Government Employees, Council 220 (Union)
Social Security Administration and AFGE Council 220 (FLRA 0-AR-5249): Step-three grievance delegation barred
The Social Security Administration delegated review of third-step grievances to officials at the same management level as second-step deciding officials. An arbitrator found that the collective-bargaining agreement gave employees access to progressively higher officials at each step and ordered the…
Rosenfeld v. Cox Enterprises, Inc.
Rosenfeld v. Cox Enterprises (DOL ARB 2016-0026): Reconsideration denied
William Rosenfeld sought reconsideration of the Board's May 2016 dismissal of his whistleblower appeal. The earlier appeal had failed because he did not challenge the administrative law judge's finding that his complaint was filed late. His reconsideration motion, filed almost a year after that…
T.S. and U.S. Postal Service, Post Office, Bloomington, IL
T.S. (ECAB 17-0386): Merit reconsideration denied
A postal carrier sought to reopen a claim involving a left shoulder condition after a slip on ice at work. His counsel repeated arguments about a previously reviewed medical report. A new report rated impairment but did not address how the accepted incident caused or aggravated the claimed…
B.C. and U.S. Postal Service, Post Office, Fairfax, VA
B.C. (ECAB 17-0092): Recurrence of disability not established
A postal rural carrier returned to limited duty after an accepted rib contusion and aggravation of sciatica. She later sought compensation for a recurrence of disability. Her doctors described pain and work restrictions, but did not adequately explain why she could no longer perform her…
K.L. and U.S. Postal Service, Post Office, Laguna Hills, CA
K.L. (ECAB 16-1490): Overpayment confirmed, amount remanded
A postal letter carrier received total disability compensation while also earning wages after returning to work. The Board agreed that this created an overpayment. It found that OWCP had counted two fewer hours of leave without pay than the employer’s records showed and had also miscalculated…
Secretary of Labor v. Bundy Auger Mining, Inc.
Highwall settlement denied for missing factual support
Bundy Auger Mining faced two specially assessed section 104(d)(1) actions involving unsafe highwall ground and inadequate working-shift examinations. The parties proposed reducing each penalty by 30 percent, for a total settlement of $4,410 instead of $6,300. Their explanation said Bundy relied on…
I.V. and Department of Homeland Security, U.S. Customs & Border Protection, Norfolk, VA
I.V. (ECAB 17-0610): Right knee condition recurrence denied
A Customs and Border Protection officer had an accepted right knee meniscal tear and later reported renewed knee symptoms. His physician attributed arthritis to the prior injury and surgery, but did not adequately explain the claimed recurrence on May 20, 2016 or its causal link to the accepted…
L.G. and Department of Homeland Security, Transportation Security Administration, East Boston, MA
L.G. (ECAB 17-0534): Lower-extremity schedule award denied
A Transportation Security Administration screener had accepted knee and back injuries and sought a schedule award. Her physician rated one percent right leg impairment, but OWCP’s medical adviser found no ratable permanent leg impairment under the applicable guide. The Board found the adviser’s…
C.S. and U.S. Postal Service, Post Office, Zanesville, OH
C.S. (ECAB 17-0496): Cashier wage-earning capacity reduction affirmed
A postal carrier received total disability compensation for accepted knee, back, and hip conditions. A second-opinion physician found that he could work full time with restrictions, and a vocational counselor identified an available sedentary cashier position. The Board found the job physically and…
C.O. and U.S. Postal Service, Post Office, Duluth, GA
C.O. (ECAB 16-1905): Medical-benefit termination reversed
A postal employee had an accepted thoracic back sprain. OWCP ended medical benefits, relying on a physician who also described serious unrelated spinal disease. That physician still attributed some muscular complaints to the work injury and could not cleanly separate their causes. The Board held…
C.O. and U.S. Postal Service, Post Office, San Antonio, TX
C.O. (ECAB 16-1775): Foot rating affirmed, knee rating remanded
A postal employee sought a schedule award for accepted right foot, ankle, and knee injuries. Both rating physicians found no permanent foot or ankle impairment. The knee record conflicted over whether he had a meniscal tear or partial meniscectomy that could be rated. The Board upheld the zero foot…
E.R. and Department of Veterans Affairs, Veterans Health Administration, North Little Rock, AR
E.R. (ECAB 16-1634): Neck and shoulder claim denial affirmed
A Veterans Affairs nurse reported upper back and shoulder symptoms after a work incident. Her physician checked a causation box and later relied on the absence of earlier symptoms. The Board found that he did not explain how the incident caused or aggravated the diagnosed conditions in light of…
J.M. and Department of Defense, Defense Intelligence Agency, MacDill Air Force Base, FL
J.M. (ECAB 16-1575): Emotional-condition claim and review requests denied
A Defense Intelligence Agency employee attributed an emotional condition to polygraph tests, duty changes, and security-related actions. The Board found no evidence that the agency had erred or abused its discretion in these administrative matters. It also upheld denial of a requested subpoena and…
Matter of L-E-A-
Family membership alone does not establish asylum nexus
The Board reviewed a Mexican respondent's appeal after an Immigration Judge denied asylum, withholding of removal, and protection under the Convention Against Torture. The Board held that an immediate family can be a particular social group, but family membership alone does not establish that the…
Atlantic Trading & Marketing, Inc.
In re Atlantic Trading & Marketing, Inc. (EAB CAA Appeal No. 17-02C): consent agreement ratified
Atlantic Trading & Marketing, Inc. resolved a Clean Air Act enforcement matter through a Consent Agreement with EPA. The Environmental Appeals Board incorporated the agreement into its Final Order and ratified it under 40 C.F.R. § 22.18(b)-(c). The Board ordered the respondent to comply with every…
Gardner v. Union Pacific Railroad Co.
Gardner v. Union Pacific Railroad (DOL ARB 2017-0025): Appeal dismissed after missed brief
David Gardner appealed an administrative law judge's dismissal of his railroad whistleblower complaint. The Board ordered him to file an opening brief by March 10, 2017 and warned that a missed deadline could lead to dismissal. He filed no brief and did not respond when the Board later ordered him…
B.O. and Department of Labor, Office of Workers’ Compensation Programs, Chicago, IL
B.O. (ECAB 17-0443): Hand and arm claim denial affirmed
A DOL employee attributed hand and arm conditions to work with compensation files. Her physician said the conditions could occur with those duties but did not provide a reasoned, sufficiently definite causal opinion. She later resubmitted the same report to seek reconsideration. The Board affirmed…
D.S. and Federal Judiciary, U.S. District Court -- East NY, Brooklyn, NY
D.S. (ECAB 17-0407): Increased wrist award request remanded
A federal court law clerk submitted a new medical rating for permanent right wrist impairment. OWCP treated the filing as a late reconsideration request and applied a clear-error standard. The Board held that evidence of increased impairment should instead be considered as a new schedule award…
S.W. and U.S. Postal Service, Post Office, Oakland, CA
S.W. (ECAB 17-0261): Mail delivery fall established, injury question remanded
A postal letter carrier said she fell down stairs after a dog startled her during a delivery. OWCP denied the claim because it found the incident unproven. The Board found her accounts consistent and sufficiently detailed to establish the fall. It returned the case for OWCP to assess the medical…
K.C. and U.S. Postal Service, Post Office, San Diego, CA
K.C. (ECAB 17-0206): Neck and shoulder occupational claim denied
A postal letter carrier attributed neck and right shoulder problems to years of lifting, carrying, and other work. His physician diagnosed shoulder and cervical conditions but described the work connection in speculative terms. The Board found the causal explanation too vague to establish the claim…
J.S. and U.S. Postal Service, Post Office, Minneapolis, MN
J.S. (ECAB 16-1769): Lumbar injury claim denial affirmed
A postal carrier twisted her back while avoiding a fall on ice. OWCP accepted that the incident occurred. A later physician attributed a recurrent disc herniation to the incident, but the Board found his opinion insufficiently reasoned given her earlier back condition and the time before he…
Secretary of Labor v. Magorian Mine Services
Mixed ruling on ground support, fall protection, and safe access
Magorian Mine Services was an independent contractor performing development work at the Pinson underground gold mine in Nevada. Judge Richard W. Manning affirmed an S&S ground-support citation because the company used inadequate support in unstable ground and allowed miners to travel through the…
Secretary of Labor v. Webster County Coal, LLC
Delayed crush-injury report affirmed, penalty cut to $20,000
A large roof rock fell onto contract miner Aaron Rickard at Webster County Coal's Dotiki Mine, causing serious pelvic and internal injuries that required multiple surgeries. Mine personnel evacuated him by air but did not notify MSHA within 15 minutes, and management continued to withhold notice as…
S.H. and Department of the Treasury, Internal Revenue Service, Richmond, VA
S.H. (ECAB 17-0703): Three percent right leg award upheld
An IRS employee received a schedule award following an accepted right knee injury. Her surgeon rated three percent permanent leg impairment, and OWCP’s medical adviser agreed. The Board found no medical evidence supporting a higher rating, despite her reported pain and limitations. It affirmed the…
J.F. and U.S. Postal Service, Post Office, Southeastern, PA
J.F. (ECAB 17-0288): PTSD claim acceptance rescinded
A postal employee had accepted physical injuries, and OWCP later added PTSD to his claim. Conflicting physicians disagreed about that diagnosis. An impartial examiner reviewed the record and found that he did not meet the PTSD criteria for the documented work events. The Board gave her reasoned…
E.W. and Department of Veterans Affairs, Dayton Veterans Medical Center, Dayton, OH
E.W. (ECAB 17-0069): Work incident accepted, injury denial upheld
A Veterans Affairs housekeeping aide said another worker pushed his cleaning cart over his feet during a fire drill. OWCP had found the event unproven. The Board found that workplace records established the incident, but the medical evidence offered only a possible foot contusion without a reasoned…
R.O. and Department of Justice, Bureau of Prisons, Atlanta, GA
R.O. (ECAB 16-1836): Overpayment waiver decision remanded
A Bureau of Prisons employee sought waiver of recovery of an overpayment. On a prior appeal, the Board set aside the fault finding for April 23 through May 2, 2015, while upholding fault for May 3 through July 25, 2015. OWCP then decided waiver using an old financial questionnaire without the…
R.E. and U.S. Postal Service, Post Office, Hartly, DE
R.E. (ECAB 16-1618): Right arm impairment rating remanded
A postal employee sought a schedule award for right arm conditions. Two examining physicians supported a 49 percent impairment rating, while a later examiner rated one percent. OWCP found the first second-opinion report inadequate but did not seek the required clarification before ordering another…
M.P. and Department of Veterans Affairs, El Paso Health Care System, El Paso, TX
M.P. (ECAB 16-1203): Written record review request restored
A Veterans Affairs nurse initially requested an oral hearing after an injury claim denial. She then timely asked for review of the written record instead. OWCP scheduled a telephone hearing and treated her nonappearance as abandonment. The Board held that the written review request controlled and…
C.S. and U.S. Postal Service, Processing & Delivery Center, Macon, GA
C.S. (ECAB 17-0502): Left arm impairment rating remanded
A postal employee sought an additional schedule award for her left arm. The Board found that OWCP physicians had inconsistently applied diagnosis based and range of motion methods when rating upper extremities. It directed OWCP to establish a consistent method and issue a new decision. The Board…
J.R. and U.S. Postal Service, Incoming Mail Center, Boston, MA
J.R. (ECAB 17-0181): Social Security offset overpayment amount remanded
A postal employee received both FECA wage-loss payments and Social Security benefits attributable to federal service. The Board found an overpayment because the required offset was missing. OWCP had used monthly offset figures where the calculation required 28-day figures. The Board remanded for a…
D.P. and U.S. Postal Service, Post Office, Southeastern, PA
D.P. (ECAB 16-1908): Right arm impairment rating remanded
A postal employee with accepted carpal tunnel syndrome and ulnar nerve compression sought a larger right arm schedule award. A second-opinion physician later gave a lower rating than the prior award, but OWCP did not send that report to its medical adviser for required review. The Board remanded to…
T.E. and U.S. Postal Service, Post Office, St. Louis, MO
T.E. (ECAB 16-1903): Injury claim denial after snow slip affirmed
A postal employee slipped on snow at work and reported pain in several parts of her body. OWCP accepted that the slip occurred. The Board found that reports of pain alone were not diagnoses and that the medical evidence did not adequately explain how the incident caused the diagnosed conditions. It…
L.N. and U.S. Postal Service, Post Office, Madison, WI
L.N. (ECAB 16-1815): Emotional-condition claim denial affirmed
A postal station manager reported stress after a meeting with the postmaster about a later work shift. The Board treated scheduling and related personnel decisions as administrative matters. It found no evidence that management acted in error or abused its discretion. It affirmed the claim denial…
M.A. and U.S. Postal Service, Post Office, Palo Alto, CA
M.A. (ECAB 16-1602): Some wage-loss dates denied, other dates remanded
A postal carrier assistant with accepted foot conditions sought compensation for intermittent absences. The Board found that several claimed disability dates lacked adequate medical support. OWCP had not considered whether other dates involved compensable time for medical treatment. The employer’s…
R.H. and Department of Transportation, Federal Aviation Administration, Washington, DC
R.H. (ECAB 16-1055): Hearing-loss claim and late hearing denial affirmed
A Federal Aviation Administration employee reported hearing loss and tinnitus after a high-pitched sound from a workplace public address system. OWCP accepted the sound incident, but the Board found no reasoned medical opinion linking it to her conditions. Her request for an OWCP hearing also…
Yantis Company
Repeat trench citation vacated for unforeseeable misconduct
A Yantis Company crew installed a sewer line in San Antonio using a trench about 9 to 10 feet deep with vertical, unprotected walls. OSHA observed an employee and later the crew foreman entering the trench without shoring, sloping, or another cave-in protection system. The judge found that OSHA…
Secretary of Labor v. The American Coal Company
Interlocutory-review request denied in settlement dispute
The Secretary sought interlocutory review after Judge William B. Moran rejected a proposed settlement covering 32 citations against The American Coal Company. The proposal preserved every citation but reduced every penalty by 30 percent, and the judge found that the Secretary still had not supplied…
United States Department of Homeland Security, Federal Law Enforcement Training Center, Glynco, Georgia (Agency) and American Federation of Government Employees, Local 2002, AFL-CIO (Incumbent Union/Petitioner) and National Treasury Employees Union (Interested Party) and American Federation of Government Employees, AFL-CIO (Intervenor/Trustee)
Federal Law Enforcement Training Center unions (FLRA AT-RP-16-0007): Affiliation petition remanded for standing findings
Members of AFGE Local 2002 voted unanimously to change their affiliation to NTEU and filed a petition to amend their certification. AFGE had imposed a trusteeship on the local shortly before the petition, and the Department of Labor later found probable cause to believe that the trusteeship had…
Riley v. El-Hajj Malik El-Shabazz Public School Academy
Riley v. El-Hajj Malik El-Shabazz (DOL ARB 2017-0036): Appeal withdrawn
Vera Riley petitioned for Board review of an administrative law judge's ruling in her Surface Transportation Assistance Act case. After the Board set a briefing schedule, Riley asked to dismiss her appeal voluntarily. Three respondents told the Board they did not object. The Board granted the…
Baker v. Union Pacific Railroad Co.
Baker v. Union Pacific Railroad (DOL ARB 2017-0034): Late appeal dismissed
Phillip Baker sought Board review of an administrative law judge's December 23, 2016 decision in his railroad whistleblower case. The Board said his petition was due January 6, 2017, but he first attempted to file after that deadline. It gave him a chance to explain why the filing period should be…
Reilly v. GlaxoSmithKline, LLC
Reilly v. GlaxoSmithKline (DOL ARB 2017-0028): Agency case dismissed after court filing
Thomas Reilly filed a Sarbanes-Oxley whistleblower complaint with OSHA in July 2015. He filed a federal district court action in May 2017 and gave the Board a copy of that complaint. The Board explained that a complainant may bring a new action in district court when the Department has not issued a…
R.N. and U.S. Postal Service, Post Office, Westhampton, NY
R.N. (ECAB 17-0497): Back injury claim returned for medical development
A postal rural carrier tripped over a mail tub and reported a back injury. One physician checked a causal box without reasoning, while a spinal surgeon explained how the fall could inflame arthritic lumbar structures. The Board found the surgeon’s opinion insufficient to prove the claim by itself…
A.B. and Department of the Treasury, Internal Revenue Service, Nashville, TN
A.B. (ECAB 17-0301): Bilateral carpal tunnel claim denied
An IRS employee attributed bilateral carpal tunnel syndrome to repetitive computer work. Her duties and diagnosis were documented, but the treating reports did not provide a reasoned causal opinion linking the condition to those duties. Another physician stated that the record did not show computer…
D.C. and Department of Veterans Affairs, Lexington Veterans Medical Center, Lexington, KY
D.C. (ECAB 16-1870): Emotional-condition claim denial affirmed
A Veterans Affairs nurse attributed stress to limited-duty assignments, work restrictions, and personnel actions. The Board found no specific regular duty proven to have caused the claim, no substantiation that she worked beyond medical restrictions, and no established error or abuse in…
C.L. and Federal Deposit Insurance Corporation, Chicago, IL
C.L. (ECAB 16-1567): Additional injury conditions not established
A Federal Deposit Insurance Corporation employee had accepted back and wrist sprains after a motor vehicle accident. He sought acceptance of additional lumbar, left thumb and wrist, and left knee conditions. The accident record contained little detail, and no physician supplied a sufficiently…
G.Z. and Department of the Navy, Navy Region Northwest Fire & Emergency Services, Port Haddock, WA
G.Z. (ECAB 16-0892): Compensation forfeiture and overpayment affirmed
A Navy employee did not report work and earnings on compensation forms covering the disputed period. The Board found that he knowingly omitted material employment information and upheld forfeiture of benefits. It also affirmed the resulting $73,241.01 overpayment and fault finding, which barred…
M.P. and U.S. Postal Service, Post Office, Haverton, PA
M.P. (ECAB 16-0551): Medical-benefit termination reversed, cervical issue remanded
A postal employee challenged termination of medical benefits from an accepted injury and sought acceptance of additional cervical conditions. The Board held that OWCP had not carried its burden to end medical benefits. It also found the impartial medical opinion on the cervical question inadequate…
Secretary of Labor v. Sunbelt Rentals, Inc.
Summary decision denied before workplace-examination hearing
A Sunbelt Rentals employee was struck and knocked unconscious by material falling inside Roanoke Cement's preheat tower while Sunbelt erected scaffolding. After an earlier Commission remand, Sunbelt sought summary decision on whether its workplace examination complied with 30 C.F.R. § 56.18002(a)…
Secretary of Labor v. Susquehanna Coal Company
Final penalty assessment reopened
Susquehanna Coal Company asked the Commission to reopen a penalty assessment that became final after the company did not contest it within 30 days. The company said the assessment went to an office that was only occasionally occupied, it could not recall receiving the assessment, and it had…
Matter of M-B-C-
Evidence can shift the burden on mandatory relief bars
The Board reviewed a Bosnian respondent's appeal after an Immigration Judge denied a waiver of deportability, asylum, and withholding of removal. The Immigration Judge found that the respondent's testimony about his military and police service during the Bosnian War was not credible, and that…
Seguin v. Northrup Grumman Systems Corp.
Seguin v. Northrup Grumman Systems (DOL ARB 2015-0038): Retaliation ruling upheld
Crisell Seguin alleged that Northrup Grumman Systems fired her after she raised concerns about company securities filings and an employee form tied to mandatory arbitration. An administrative law judge found that her complaints and refusal to sign the form were protected under the Sarbanes Oxley…
Tocci v. Miky Transport
Truck safety complaint remanded
Joe Tocci complained to Miky Transport about safety problems with his assigned truck, including low beam headlights that did not adequately light the road. After the company fired him, a judge dismissed his Surface Transportation Assistance Act retaliation complaint. The Board agreed that his…
S.H., widow of P.H., and Department of Justice, Drug Enforcement Administration, Kunduz Province, Afghanistan
S.H., widow of P.H. (ECAB 17-0418): Survivor-benefits denial affirmed
A Drug Enforcement Administration special agent died following intestinal perforation, ulcerative colitis, and advanced colon cancer. His widow sought survivor benefits based on conditions she attributed to his work in Afghanistan. The Board acknowledged evidence of hazardous air and pollutants…
D.P. and U.S. Postal Service, Main Post Office, Grand Rapids, MI
D.P. (ECAB 17-0148): Right shoulder occupational claim denied
A postal rural carrier attributed a right shoulder condition to years of repetitive use and lifting. Her physician listed shoulder diagnoses and said work could have caused them, but did not provide a sufficiently definite, reasoned explanation tied to the accepted duties. The Board affirmed the…
Z.S. and Department of the Air Force, Aeronautical Systems Center, Wright-Patterson Air Force Base, OH
Z.S. (ECAB 16-1745): Late reconsideration request denied
An Air Force employee requested reconsideration of an earlier decision about a left hip condition. Her request was dated before the deadline but reached OWCP three days after it. The Board applied the receipt-date rule and found that the submitted material did not clearly establish error in the…
M.S. and U.S. Postal Service, Post Office, San Francisco, CA
M.S. (ECAB 16-1743): Left knee arthritis claim denial affirmed
A postal employee claimed that work aggravated arthritis in her left knee. Her physician described repetitive bending and other duties, but his causal analysis addressed the right knee and hips. The Board found that the report did not explain how work affected the left knee condition at issue. It…
D.C. and Department of the Navy, Joint Base Anacostia-Bolling, Washington, DC
D.C. (ECAB 16-1457): Deep vein thrombosis claim denial affirmed
A Navy police officer attributed right leg deep vein thrombosis to long periods of sitting in a patrol car and standing. OWCP accepted those work activities. His physician diagnosed the condition and attributed it to immobility but did not explain the medical mechanism connecting the actual duties…
R.G. and U.S. Postal Service, Post Office, Elizabeth, NJ
R.G. (ECAB 16-0271): Wage-loss and medical benefit terminations affirmed
A postal employee had accepted costochondral and trapezius injuries. OWCP ended wage-loss and medical benefits after finding that the accepted conditions no longer caused disability or required treatment. The Board found the termination supported by the medical evidence. Later reports did not…
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.