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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E.K. and U.S. Postal Service, Post Office, St. Louis, MO
E.K. (ECAB 14-1600): Exam obstruction suspended development, not award claim
E.K., a postal employee, did not cooperate with a medical examination needed to rate his impairment. OWCP denied his schedule award claim on that basis. The Board held that obstruction suspended further development until he cooperated but did not justify final denial. It reversed OWCP's decision…
U.S. Silica Company v. Secretary of Labor and Secretary of Labor v. U.S. Silica Company
Highwall violations affirmed with $22,248 penalty
A large slope failure at U.S. Silica's West Virginia surface mine covered a bench and the only access road into the pit, yet the company cleared the road and resumed work without maintaining the highwall or preventing another slide. Judge Margaret A. Miller affirmed an S&S highwall-maintenance…
Secretary of Labor v. Empire Iron Mining Partnership
Eighteen citations settled and continuity-testing citation vacated
Empire Iron Mining's docket contained 19 citations with proposed penalties of $19,031, including a continuity-testing citation that had remained stayed for years while similar litigation proceeded. Judge Jerold Feldman vacated that $176 citation without prejudice because it had been promptly…
T.S. and Department of Veterans Affairs, Veterans Benefits Administration, Detroit, MI
T.S. (ECAB 15-1119): Knee claim review and hearing refusals upheld
T.S., a VA personnel specialist, had claimed a knee injury after slipping near an elevator. She sought reconsideration and an oral hearing. The Board found that her reconsideration request did not qualify for merit review and that OWCP acted within its discretion in denying a hearing. It affirmed…
G.G. and U.S. Postal Service, Airport Mail Center, Boston, MA
G.G. (ECAB 15-1038): Ankle impairment rating needs explanation
G.G., a postal mail handler, sought more than four percent left leg impairment after an accepted ankle injury. The Board found that the medical adviser had not adequately explained why he selected the category for mild motion deficits within class 1 despite the examiner’s findings of ankle…
J.G. and U.S. Postal Service, Post Office, Humacao, PR
J.G. (ECAB 15-1034): Seven percent leg impairment award upheld
J.G., a postal sales associate, sought a larger award after a right knee injury and surgery. The Board found that the medical evidence did not establish more than seven percent right leg impairment. It also upheld the date used for maximum medical improvement. The Board affirmed the award.
F.D. and U.S. Postal Service, Post Office, Wappingers Falls, NY
F.D. (ECAB 15-0868): Mail-tray back injury lacked causal opinion
F.D., a city carrier assistant, reported back pain after bending into a hamper to place a mail tray. The Board accepted the workplace incident but affirmed OWCP's denial of his injury claim. His chiropractor diagnosed a spinal subluxation without an x-ray demonstrating it, so the Board could not…
K.S. and Department of the Army, Medical Command, Fort Shafter, HI
K.S. (ECAB 15-0741): Back injury schedule award lacked impairment rating
K.S., an Army receptionist, sought compensation for permanent impairment after accepted back injuries. She reported ongoing pain but had not submitted a physician's valid permanent impairment rating. The Board held that symptoms alone did not establish entitlement to a schedule award. It affirmed…
D.K. and U.S. Postal Service, Post Office, Harrisburg, PA
D.K. (ECAB 15-0665): Disability recurrence lacked work-specific proof
D.K., a postal mail clerk, sought renewed disability benefits after an accepted back and leg injury from lifting a parcel. The Board found no medical opinion supported by objective findings and addressing her actual job duties that established disability beginning June 17, 2014. It affirmed OWCP's…
S.R. and U.S. Postal Service, Post Office, Trenton, NJ
S.R. (ECAB 15-0580): Short disability period paid but prolonged claim denied
S.R., a postal letter carrier, claimed prolonged disability after an accepted January 2012 injury. The Board found the medical evidence insufficient to establish disability for the extended period. It also found support for wage-loss compensation for as much as two months immediately after the…
R.B. and Department of the Navy, Fleet Readiness Center East, Cherry Point, NC
R.B. (ECAB 15-0420): Suitable work refusal supported termination
R.B., a Navy aircraft mechanic with accepted injuries, refused an offered position. The Board found the job suitable under his medical restrictions and rejected his objections to the offer. It held that OWCP properly applied the suitable-work rule. The Board affirmed termination of wage-loss…
B.H. and U.S. Postal Service, Post Office, Jersey City, NY
B.H. (ECAB 15-0091): Ankle termination upheld; knee condition remanded
B.H., a postal mail handler, had an accepted ankle contusion after tripping while unloading mail. The Board found that OWCP properly ended benefits when that accepted condition resolved. It also found conflicting medical opinions about whether the same event caused a left knee condition. The Board…
F.M. and U.S. Postal Service, Post Office, Lenox Hill, NY
F.M. (ECAB 15-1176): Suitable work and reconsideration rulings upheld
F.M., a postal letter carrier with accepted injuries, refused an offered suitable job. The Board upheld termination of his wage-loss and schedule award compensation on that basis. It also found that his later reconsideration arguments had already been considered and did not warrant reopening. It…
W.W. and Department of Homeland Security, Citizenship and Immigration Services, Lee's Summit, MO
W.W. (ECAB 15-1130): Specialist needed for workplace injury claim
W.W., a Homeland Security information security officer, reported symptoms after a workplace event in October 2012. The Board found the record sufficient to require more medical development, including possible aggravation of earlier conditions. It directed OWCP to seek a specialist's reasoned…
J.H. and U.S. Postal Service, Post Office, Bellmawr, NJ
J.H. (ECAB 15-0899): Seven percent right leg award upheld
J.H., a postal letter carrier, sought a larger schedule award after accepted right Achilles and foot conditions. The Board found no medical evidence showing more than seven percent permanent right leg impairment. A later lower rating did not add to the existing award. It affirmed OWCP's decision.
K.M. and Department of Homeland Security, U.S. Coast Guard, Honolulu, HI
K.M. (ECAB 15-0886): Ankle disease claim lacked reasoned medical link
K.M., a Coast Guard maintenance worker, claimed that years of lifting, stairs, and uneven ground caused or worsened his left ankle conditions. One physician diagnosed degenerative disease but gave no opinion on work causation. Another connected the condition to work without adequately…
W.T. and Department of the Army, Fort Riley, KS
W.T. (ECAB 15-0827): Vaccination injury lacked causal medical proof
W.T., an Army management analyst, reported right arm symptoms after required preemployment vaccinations. The Board accepted that the vaccinations occurred in the performance of duty but found no reasoned medical opinion diagnosing and linking an injury to them. His later reconsideration request…
L.S. and U.S. Postal Service, Post Office, Brooklyn, NY
L.S. (ECAB 15-0779): Knee disease claim lacked medical rationale
L.S., a postal letter carrier, attributed bilateral knee conditions to climbing and descending stairs at work. The Board accepted that she climbed stairs at work. Her physician diagnosed knee conditions and stated they were work related but did not explain medically how the duties caused or…
A.B. and Department of Veterans Affairs, Central California Health System, Fresno, CA
A.B. (ECAB 15-0613): Late schedule award review showed no clear error
A.B. challenged the pay rate OWCP used for a prior schedule award. Her reconsideration request arrived more than one year after the January 2013 merit decision, so OWCP applied the clear-error standard. The Board found that she did not explain why the later pay rate she proposed controlled under…
L.S. and U.S. Postal Service, Post Office, South Hackensack, NJ
L.S. (ECAB 15-0414): Overpayment upheld; recovery rate remanded
L.S., a postal employee, received compensation that overlapped with retirement benefits. The Board upheld OWCP's finding of a $10,684.11 overpayment and that he was at fault, which barred waiver. It set aside the $300 deduction rate because OWCP had not considered financial information he submitted…
C.I. and U.S. Postal Service, Post Office, Coppell, TX
C.I. (ECAB 15-0285): Conflicting limb ratings require impartial examination
C.I., a postal mail processing clerk, had accepted left knee, leg, wrist, and pain conditions. OWCP awarded 13 percent left arm impairment and found no ratable left leg impairment. Her physician rated both limbs substantially higher, creating a medical conflict with OWCP's examiner. The Board…
L.G. and U.S. Postal Service, Post Office, White Plains, NY
L.G. (ECAB 15-0125): Conflicting accounts defeated shoulder injury claim
L.G., a postal mail handler, said she reinjured her shoulder while working with mail on June 2, 2013. Her description of the incident conflicted with statements from coworkers and a contemporaneous emergency room record that reported no recalled injury. The Board found serious doubt about whether…
Georgia Carolina Stucco, Inc.
Three repeat scaffold violations affirmed
Georgia Carolina Stucco used another contractor's scaffolds while applying stucco to an assisted-living facility in Evans, Georgia. Three employees, including the company's foreman and competent person, worked as high as 20 feet 9 inches on platforms that were not fully planked and had no…
Secretary of Labor v. Conshor Mining, LLC
Bankruptcy and dissolution made penalty cases moot
Seven dockets involving 16 citations and proposed penalties of $1,193,659 had remained stayed while the Commission considered unresolved questions about repeated flagrant violations. During the delay, Conshor Mining completed Chapter 7 bankruptcy, dissolved under Kentucky law, and had nearly all of…
Secretary of Labor v. TXI Operations, LP
Settlement denied for unsupported guarding reductions
The Secretary proposed resolving a seven-citation docket by vacating three citations, settling two at their original amounts, and reducing the penalties and findings on two machine-guarding citations. Judge William B. Moran held that the motion merely repeated TXI Operations' assertions and did not…
Moore v. National Railroad Passenger Corp.
Moore v. Amtrak (DOL ARB 2015-0041): rail injury reporting settlement approved
John Moore alleged that Amtrak retaliated against him for reporting a work-related injury. An administrative law judge found a Federal Railroad Safety Act violation and awarded damages, and Amtrak petitioned the Board for review. Before the Board decided that appeal, the parties submitted a…
J.B. and Department of Homeland Security, Immigration and Customs Enforcement, Boston, MA
J.B. (ECAB 15-1043): Overpayment waiver denied despite lack of fault
J.B., a federal investigator, received an extra compensation payment after returning to work. OWCP found him without fault but denied waiver of the $6,336.12 overpayment. The Board found that his assets exceeded the hardship threshold and that purchases made with the money did not show a loss from…
J.A. and Department of Agriculture, Food Safety and Inspection Service, Moultrie, GA
J.A. (ECAB 15-0908): Back benefits termination and later denial upheld
J.A., a federal poultry inspector, received benefits for an accepted back condition. The Board found OWCP's referral examiner gave a reasoned basis for concluding that the accepted condition had resolved by March 2012. Later treating reports did not adequately connect his continuing symptoms or…
V.R. and Department of Veterans Affairs, Philadelphia Veterans Administration Medical Center, Philadelphia, PA
V.R. (ECAB 15-0883): No new basis to reopen emotional-condition claim
V.R. sought reconsideration of an emotional-condition claim. The Board could review only OWCP's nonmerit reconsideration decision in this appeal. Her request identified no new legal error or argument, and she submitted no additional evidence. The Board affirmed the refusal to reopen without…
C.J. and Department of State, Foreign Service Institute, Washington, DC
C.J. (ECAB 15-0589): Disability recurrence lacked link to accepted condition
C.J. claimed he became disabled again in April 2014 after an accepted bilateral carpal tunnel condition. His physicians described worsening arm symptoms, typing difficulty, and separate ulnar nerve conditions. The Board found their opinions did not adequately explain how the new disability was…
R.B. and U.S. Postal Service, Post Office, Ithaca, NY
R.B. (ECAB 15-0192): Retirement overlap debt and recovery rate upheld
R.B., a postal employee, received FECA compensation while also receiving Social Security retirement benefits attributable to federal service. The Board upheld OWCP's $12,088.11 overpayment calculation and found that he was at fault because he inaccurately reported the benefits on disclosure forms…
L.H. and U.S. Postal Service, Post Office, Raleigh, NC
L.H. (ECAB 14-0798): No new medical proof to reopen vascular claim
L.H., a postal mail expeditor, sought reconsideration of a claim concerning an aneurysm and embolic condition after an accepted back and leg injury. The Board found that the underlying issue required medical evidence about work causation. His request supplied no new medical evidence or relevant new…
Spartan Mining Company v. Secretary of Labor
More facts required for imminent-danger ruling
Spartan Mining and the Secretary asked the Judge to resolve an imminent-danger order through cross-motions for summary decision after settling a related citation. Their stipulations did not establish the size of the danger area, how many people were withdrawn, the timing between the inspector's…
Secretary of Labor v. MaRyan Mining, LLC
Two S&S violations reduced to $1,000 total
Four contractor employees entered a worked-out panel during an unexpected shift without a required preshift examination, and an inspector later found two loose ribs and a damaged roof bolt in the area. Judge Priscilla M. Rae affirmed both the preshift-examination and roof-and-rib-control violations…
Matter of D-M-C-P-
Biometrics notice is required before abandonment
The Board reviewed an Argentine applicant's asylum-only proceedings after an Immigration Judge ruled that he had abandoned his applications for asylum, withholding of removal, and Convention Against Torture protection because his fingerprints were taken only four days before the hearing. The Board…
G.S. and Department of Veterans Affairs, Veterans Administration Medical Center, Jacksonville, FL
G.S. (ECAB 15-1029): Late reconsideration showed no clear error
G.S., a VA nurse, attributed symptoms to fumes from workplace cleaning products. She asked OWCP to reconsider its earlier claim denial after the one-year deadline. The Board found that her submission did not show clear error in the earlier merits decision. It affirmed the untimely reconsideration…
B.F. and U.S. Postal Service, Post Office, Decatur, GA
B.F. (ECAB 15-0975): Reconsideration lacked new evidence or argument
B.F., a postal sales and distribution worker, claimed hand conditions from repetitive mail duties. After OWCP denied the occupational disease claim, she sought reconsideration. The Board found no new pertinent evidence, new legal argument, or showing of legal error in the request. It affirmed the…
H.H. and Department of Veterans Affairs, Veterans Administration Medical Center, Little Rock, AR
H.H. (ECAB 15-0947): Claimed work aggravation requires fuller record
H.H., a VA emergency room administrative assistant, claimed that duties outside her restrictions aggravated accepted neck, arm, and hand conditions. Supervisor and coworker statements supported her account of staffing shortages and missed breaks. A physician also discussed how repetitive motions…
M.B. and Department of Homeland Security, La Guardia Airport, East Elmhurst, NY
M.B. (ECAB 15-0925): Ankle claim not reopened on repetitive evidence
M.B., an airport security officer, sought reconsideration after OWCP denied an ankle injury claim arising from a fall near a stanchion. Her new police report repeated the existing account, and other medical reports were duplicative. The Board found the arguments about security video and a withdrawn…
H.A. and Department of the Air Force, Tinker Air Force Base, OK
H.A. (ECAB 15-0833): Wrist disease claim lacked causal explanation
H.A., an Air Force fire protection inspector, claimed wrist and nerve conditions from equipment inspection and computer duties. The Board accepted those duties but found no physician adequately explained how they caused the diagnoses. That explanation was especially needed in light of a prior wrist…
J.D. and U.S. Postal Service, Los Angeles International Airport Post Office, Los Angeles, CA
J.D. (ECAB 15-0305): Wage capacity finding needs accepted-condition review
J.D., a postal tractor trailer operator, received compensation after accepted back and knee injuries. OWCP reduced his benefits based on capacity to work as an information clerk. The Board found uncertainty about whether a disc condition was also accepted, while the impartial examiner had…
L.D. and U.S. Postal Service, Post Office, Philadelphia, PA
L.D. (ECAB 15-0220): Cervical and recurrence claims denied; rating remanded
L.D., a postal clerk, appealed rulings on cervical disease, renewed disability, and a right arm schedule award. The Board found that she had not proved either a work-related cervical condition or disability recurrence beginning May 27, 2010. It found the record insufficient to decide whether her…
Secretary of Labor v. Concrete Mobility, LLC
Unexplained delay barred reopening defaults
Concrete Mobility defaulted after failing to answer two penalty petitions and related show-cause orders. The company later said its mine personnel did not understand MSHA procedures and asked the Commission to reopen the cases, while the Secretary opposed because collection activity had already…
S.M. and U.S. Postal Service, Post Office, Sullivan, OH
S.M. (ECAB 15-1118): Shoulder recurrence lacked dated medical proof
S.M., a postal mail carrier, claimed disability and wage loss from August through November 2014 after an accepted shoulder injury. Her physician noted ongoing shoulder problems and inability to work but did not explain how the accepted condition caused disability during the specific dates claimed…
M.M. and U.S. Postal Service, Carol Stream Post Office, Carol Stream, IL
M.M. (ECAB 15-1093): Late oral hearing request properly denied
M.M. requested a hearing concerning a schedule award more than 30 days after OWCP issued its September 2014 decision. The Board found the request untimely and held that OWCP reasonably exercised its discretion to decline a late hearing. Her statement that she received the decision in October did…
F.J. and U.S. Postal Service, Main Post Office, Atlanta, GA
F.J. (ECAB 15-1050): New wrist opinion required merits review
F.J. sought reconsideration of a wrist tendinitis claim. His physician submitted a new addendum explaining how repeated lifting of mail caused tendon inflammation. The Board held that this relevant medical opinion met the threshold for reopening. It did not decide entitlement. It directed OWCP to…
G.B. and U.S. Postal Service, Post Office, Cleveland, OH
G.B. (ECAB 15-1039): New nerve test required award review
G.B. sought a schedule award for upper extremity impairment. OWCP had denied the claim partly because an examination found no evidence of cervical nerve root involvement. He then submitted a new electrodiagnostic study showing left C6 radiculopathy. The Board held that this evidence was relevant to…
B.T. and U.S. Postal Service, Fort Dearborn Station, Chicago, IL
B.T. (ECAB 15-0956): Conflicting knee ratings need impartial review
B.T. received a 23 percent left leg schedule award after accepted aggravation of knee conditions and knee replacement. Her physician rated impairment at 31 percent, while OWCP's medical advisers supported 23 percent. The Board found their opinions equally weighty and directed OWCP to obtain an…
L.M. and Department of the Air Force, Randolph Air Force Base, TX
L.M. (ECAB 15-0818): Hearing loss award and hearing aids denied
L.M. had accepted work-related hearing loss but sought a schedule award and hearing aids. The Board found the new audiograms lacked physician certification and did not establish ratable impairment. A physician recommended hearing aids without explaining why they were needed for the accepted loss…
J.S. and U.S. Postal Service, Post Office, Lawrence, MA
J.S. (ECAB 15-0619): Hip arthritis aggravation lacked causal proof
J.S., a postal carrier, attributed bilateral hip arthritis to years of standing, walking, stairs, and lifting. The Board found that his physician did not adequately assess other possible causes, including congenital disease and a prior traumatic injury, or explain how work aggravated the arthritis…
J.S. and U.S. Postal Service, Post Office, Lawrence, MA
J.S. (ECAB 15-0619): Erratum corrects hip decision and directs reissue
The Board identified incorrect wording in the analysis of its earlier decision about J.S.'s hip condition. The erratum replaced a passage suggesting OWCP misapplied the causation standard with wording stating that OWCP applied it properly. The Board directed reissue of the corrected decision. The…
C.P. and U.S. Postal Service, Post Office, Estero, FL
C.P. (ECAB 15-0617): Nerve injury benefits termination upheld
C.P., a postal employee, had accepted carpal tunnel and ulnar nerve conditions. The Board credited a reasoned second opinion that those work-related conditions had resolved by September 2012. Later medical reports described symptoms but did not adequately explain disability or residuals from the…
P.H. and U.S. Postal Service, Bulk Mail Center, Denver, CO
P.H. (ECAB 15-0482): Later psychological injury claim lacked causal proof
P.H. claimed that a March 24, 2000 event caused a consequential psychological injury after an earlier accepted workplace injury. After an earlier remand, OWCP reviewed physician depositions that counsel had submitted with a reconsideration request about that event. The Board found the opinions did…
Local 5929, United Mine Workers of America v. Big Ridge, Inc.
Unanswered motion ended miner compensation claim
After a roof fall idled the Willow Lake Mine under a section 103(k) order, the union sought one week's compensation for 142 miners and argued that MSHA should have used a section 107(a) withdrawal order. Big Ridge moved for summary decision, contending that section 111 compensation did not apply to…
Secretary of Labor v. Kentucky Fuel Corporation
Unsupported 97% flyrock settlement reduction denied
Kentucky Fuel was cited for failing to follow its ground-control plan's flyrock precautions when it drilled seven rows of blast holes where the plan allowed no more than four. The Secretary proposed reducing the specially assessed $30,200 penalty to $1,000 and changing the citation from S&S, highly…
S.A. and Department of the Navy, Child Development Center, Joint Base Anacostia-Bolling, Washington, DC
S.A. (ECAB 15-1092): Back injury event lacked causal medical proof
S.A. reported a back injury during an accepted workplace incident on December 19, 2013. The Board found that a physician diagnosed a contusion and spasm without explaining causation, while other records described only pain or lacked a qualified physician's opinion. The evidence did not establish…
B.W. and U.S. Postal Service, Post Office, Great Falls, MT
B.W. (ECAB 15-1045): Mail-tub wrist injury lacked medical explanation
B.W., a postal employee, developed right wrist symptoms while pulling tubs of mail on August 5, 2013. The Board accepted that the incident occurred. Her physician diagnosed tendinitis and called it work related but did not explain the medical mechanism connecting the work to the condition. The…
J.W. and U.S. Postal Service, Post Office, Lincolnwood, IL
J.W. (ECAB 15-1036): Foot award claim not reopened without new medical proof
J.W. sought reconsideration after OWCP found insufficient evidence for a right foot schedule award. Her request called for more testing and described her injury but supplied no relevant new medical evidence about permanent impairment. The Board found no new legal argument or showing of error…
D.N. and U.S. Postal Service, Syracuse Postal and Distribution Center, Syracuse, NY
D.N. (ECAB 15-0987): Wrist incident lacked diagnosis; review refusal upheld
D.N., a postal mechanic, struck his right hand or wrist while retrieving a package at work. The Board accepted that the incident occurred but found no medical diagnosis of a resulting condition; a report assessing only a wrist injury was insufficient. His reconsideration submission repeated…
J.C. and U.S. Postal Service, Post Office, City of Industry, CA
J.C. (ECAB 15-0841): Home fall and wage-loss claim need development
J.C., a postal employee with accepted spine and nerve conditions, claimed disability after a fall at home caused compression fractures. Physicians suggested that weakness from his accepted conditions may have contributed to the fall. The Board found that OWCP had not adequately developed that…
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.