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.
No decisions match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
David G. Newton-Sealey v. ArmorGroup (Jersey) Services, Limited
Newton-Sealey v. ArmorGroup (BRB 12-0446 and 12-0446A): benefits cutoff after UK settlement reconsidered
David Newton-Sealey provided security for engineers in Iraq and was injured when his vehicle rolled over after a collision. He later settled a UK lawsuit with three related ArmorGroup companies without prior written approval from the carrier paying his Defense Base Act benefits. An administrative…
C.B. and Department of Veterans Affairs, Veterans Administration Medical Center, Fayetteville, NC
C.B. (ECAB 13-694): Patient transfer incident did not establish back injury
C.B., a Veterans Affairs nuclear medicine technologist, reported back and buttock symptoms after helping a patient transfer to a wheelchair. The work incident was accepted, but the medical records also described preexisting degenerative disc disease. His physician said the incident aggravated that…
K.R. and U.S. Postal Service, Processing and Distribution Center, Boston, MA
K.R. (ECAB 13-540): Knee injury claim lacked reasoned medical link to work
K.R., a Postal Service mail handler, reported right knee pain while transporting a bulk mail container. His physician diagnosed a medial collateral ligament strain and subchondral contusion, and imaging also showed prior degenerative changes. The Board found that the physician’s statement linking…
J.T. and U.S. Postal Service, Four Peaks Post Office, Mesa, AZ
J.T. (ECAB 13-452): Walk-in tub request and late record review denied
J.T., a Postal Service employee with accepted foot conditions and left leg reflex sympathetic dystrophy, requested a walk-in tub and home modification costing $19,662.50. The Board found that the request lacked a qualifying physician’s explanation of medical necessity, while OWCP’s examiner…
D.B. and Department of the Treasury, Internal Revenue Service, Oakland, CA
D.B. (ECAB 13-362): Sitting duties not medically linked to lumbar conditions
D.B., an IRS collection representative, claimed that prolonged sitting and telephone work caused or worsened her back condition. The Board accepted those work duties and noted diagnoses of lumbar sprain, degenerative disc disease, and sciatica. A treating physician generally attributed her symptoms…
G.J. and U.S. Postal Service, Post Office, Richmond, CA
G.J. (ECAB 13-248): Wrist claim denied for lack of medical link to file cabinet incident
G.J., a Postal Service custodian, reported a right wrist injury from moving a heavy file cabinet in December 2010. Physicians diagnosed a wrist strain when they examined him more than 18 months later. The Board found that neither physician gave a definite, reasoned explanation connecting the remote…
A.R. and Department of Homeland Security, Immigration and Customs Enforcement, Brownsville, TX
A.R. (ECAB 13-240): Twenty percent lung impairment award upheld
A.R., an Immigration and Customs Enforcement employee, had accepted bronchitis and pneumonitis from workplace fume exposure and sought a larger lung schedule award. Earlier medical opinions conflicted, so OWCP obtained an impartial pulmonology evaluation and a supplemental report. The Board…
V.K. and U.S. Postal Service, Post Office, Oakland, CA
V.K. (ECAB 13-55): Recurrence denial upheld after modified work was withdrawn
V.K., a Postal Service mail processor, injured her chest and right shoulder in a June 2011 fall. She returned to full duty in September, then resumed modified work with new restrictions. When the Postal Service had no work within those restrictions, she claimed disability beginning December 3…
Digco Utility Construction
Repeat excavation items vacated
Digco excavated to locate a gas line when an OSHA officer saw the top of a worker's hard hat from the road. By the time the officer reached the site, the foreman had deepened the excavation to 6½ feet, but no employee was inside it. The judge credited testimony that the worker had entered only…
D.B. and Department of Veterans Affairs, Veterans Administration Medical Center, Bronx, NY
D.B. (ECAB 12-1353): Denial of assault injury claim upheld
D.B., a Veterans Affairs program support assistant, said an elderly man struck her near the medical center elevators after she mistakenly took his belongings from the cafeteria. She claimed a low back injury. The Board found that her account of repeated blows differed from a witness’s initial…
Eastern Associated Coal, LLC v. Secretary of Labor
Belt accumulations and failed examination upheld
An MSHA inspector found extensive coal accumulations beneath a longwall belt take-up, with rollers turning in compacted coal and three frozen rollers. Judge Jacqueline R. Bulluck upheld the accumulation citation as significant and substantial, highly negligent, and an unwarrantable failure because…
Wal-Mart Stores, Inc.
In re Wal-Mart Stores, Inc. (EAB RCRA (3008) 13-01C and FIFRA 13-03C): $7,628,000 penalty approved
Wal-Mart Stores, Inc. was the respondent in consolidated EPA proceedings under the Resource Conservation and Recovery Act and the Federal Insecticide, Fungicide and Rodenticide Act. The EPA and Wal-Mart signed and consented to entry of a Consent Agreement. The Board incorporated that agreement into…
Wal-Mart Stores, Inc.
In re Wal-Mart Stores, Inc. (EAB RCRA (3008) 13-01C and FIFRA 13-03C): $7,628,000 penalty approved
Wal-Mart Stores, Inc. was the respondent in consolidated EPA proceedings under the Resource Conservation and Recovery Act and the Federal Insecticide, Fungicide, and Rodenticide Act. The EPA and Wal-Mart signed and consented to entry of a Consent Agreement. The Board incorporated that agreement…
Secretary of Labor v. Webster County Coal, Warrior Coal, LLC, Hopkins County Coal, LLC, and River View Coal, LLC
Dry-hole citations vacated for lack of fair notice
MSHA cited four related coal operators for mining near 117 old boreholes and for failing to label them as oil or gas wells on mine and ventilation maps. None of the holes had produced oil or gas, all were listed as dry and abandoned, and MSHA had inspected the mines for years without previously…
M.R. and U.S. Postal Service, Post Office, Grand Rapids, MI
M.R. (ECAB 13-460): Back condition claim denied for lack of medical explanation
M.R., a Postal Service mail handler, claimed that lifting, bending and twisting at work caused a herniated lumbar disc and nerve symptoms. Imaging and physician reports documented a back condition. One neurosurgeon said the injury most likely resulted from work, but he did not describe her duties…
V.L. and U.S. Postal Service, Post Office, Lexington, KY
V.L. (ECAB 13-394): Trigger thumb claim denial upheld
V.L., a Postal Service letter carrier, claimed that routinely casing and delivering mail caused trigger thumb in both hands. Her physician documented the condition and examination findings. The Board accepted the described work activities but found no medical opinion explaining how those activities…
S.Z. and U.S. Postal Service, Post Office, Norcross, GA
S.Z. (ECAB 13-111): Knee injury claim denial upheld
S.Z., a Postal Service city carrier, said she twisted her left knee while nearly falling at work on October 27, 2011. OWCP accepted that the incident occurred, but disputed that it caused her meniscal tear. The Board found that her treating surgeon had not addressed earlier knee complaints and…
S.Z. and U.S. Postal Service, Post Office, Norcross, GA
S.Z. (ECAB 13-110): Occupational knee claim denial upheld
S.Z., a Postal Service city carrier, claimed that prolonged standing and stepping from a postal vehicle contributed to a left knee injury. OWCP treated the claim as an occupational disease because the alleged work factors extended over more than one shift. Her doctors diagnosed a meniscal tear and…
I.P. and Office of Personnel Management, Employee & Labor Relations, Washington, DC
I.P. (ECAB 13-638): Suspension for missing earnings report upheld
I.P., a retired Office of Personnel Management employee receiving compensation, did not return OWCP’s 2012 affidavit about his work and earnings. OWCP sent the form and a 30-day warning to his address of record, then suspended wage-loss benefits. I.P. said a family emergency delayed his mail and…
R.W. and Department of Veterans Affairs, Veterans Health Administration, Portland, OR
R.W. (ECAB 13-529): Late request for written review denied
R.W., a Veterans Affairs social worker, sought benefits for an emotional condition related to her work. OWCP denied the claim in March 2012. She requested a review of the written record in October, more than 30 days after that decision. The Board found no evidence that OWCP had received an earlier…
R.H. and U.S. Postal Service, Post Office, Knoxville, TN
R.H. (ECAB 13-245): Back injury claim denial upheld
R.H., a Postal Service rural carrier, said lifting a heavy package on her route caused low back and right leg symptoms. OWCP accepted that the lifting occurred but denied her injury claim. The Board found that one doctor addressed a different reported incident, while her surgeon mentioned a work…
B.G. and U.S. Postal Service, Post Office, Bakersfield, CA
B.G. (ECAB 13-54): Denial of back aggravation claim upheld
B.G., a Postal Service city carrier, claimed that lifting, bending and twisting at work aggravated a back condition from an earlier motor vehicle accident. One doctor described work restrictions and said prolonged activity could aggravate back muscles, but did not address whether work caused her…
W.T. and U.S. Postal Service, Post Office, Birmingham, AL
W.T. (ECAB 12-1743): Termination of compensation upheld
W.T., a former Postal Service letter carrier, received compensation for a low back strain and a consequential psychiatric condition after a 1985 injury. OWCP had previously ended medical benefits for the resolved back strain and later terminated compensation for the psychiatric condition. The Board…
D.S. and U.S. Postal Service, Post Office, Malakoff, TX
D.S. (ECAB 12-1641): Wage capacity reconsideration sent back to OWCP
D.S., a Postal Service rural carrier with accepted arm and shoulder injuries, had a wage-earning capacity decision that reduced her compensation to zero after she returned to modified work. She later sought compensation when the Postal Service had no work for her under its National Reassessment…
J.T. and U.S. Postal Service, Post Office, Babylon, NY
J.T. (ECAB 12-1313): Wage-loss denial upheld after light duty ended
J.T., a Postal Service mail carrier, worked in a light-duty position after an accepted arm and shoulder injury. The Postal Service later withdrew that position under the National Reassessment Process, and she sought wage-loss compensation. OWCP found its earlier wage-earning capacity decision…
Secretary of Labor v. Pay Car Mining, Inc.
Two assessments reopened after reported medical disruption
Pay Car Mining's representative said he placed two proposed assessments in his secretary's work box for contest and that unforeseen medical developments prevented timely filing. The Secretary did not oppose reopening but urged the representative to adopt procedures that would keep personal…
Secretary of Labor on behalf of Burdette Billings v. FTS International Proppants, LLC
Independent misconduct defeated discrimination claim
Burdette Billings complained to management and MSHA that miners had to stand in very hot discharged sand without adequate protection. FTS fired him five days after his MSHA complaint, citing equipment-rule violations, property damage, an off-duty mine visit, and confrontational conduct at a town…
Warrior Coal, LLC v. Secretary of Labor
Icy walkway citation reduced from fatal gravity
A Warrior Coal employee slipped on an icy walkway, fractured his ankle, experienced severe respiratory complications after surgery, and died several weeks later. Judge Jacqueline R. Bulluck held that Warrior violated the walkway standard because it lacked effective ice-removal procedures and could…
J.H. and Department of the Interior, Bureau of Reclamation, Sacramento, CA
J.H. (ECAB 13-652): Knee recurrence claim denial upheld
J.H., a former Bureau of Reclamation maintenance worker, had an accepted right knee injury from 1982 and later sought benefits for a claimed recurrence. A 2012 orthopedic report documented advanced degenerative changes and suggested that the earlier injury and surgeries could explain them. The…
P.T. and Department of Veterans Affairs, Veterans Administration Medical Center, Jackson, MS
P.T. (ECAB 13-429): Back injury claim denial upheld
P.T., a Veterans Affairs nurse, reported back pain after changing a resident’s diaper and removing linen during a June 2012 shift. OWCP accepted that the incident happened but denied her injury claim for lack of medical proof of causation. The Board corrected OWCP’s view of the chiropractor’s…
K.J. and Department of Veterans Affairs, Veterans Health Administration, Salem, VA
K.J. (ECAB 13-271): Injury denial affirmed with corrected grounds
K.J., a Veterans Affairs nursing assistant, reported that a patient struck his chest and back during a shift. OWCP denied his injury claim, saying the incident was unproved and the record lacked a physician’s diagnosis. The Board found the consistent reports established the incident and identified…
L.D. and U.S. Postal Service, Post Office, Tampa, FL
L.D. (ECAB 13-182): Medical conflict over back aggravation sent for impartial review
L.D., a former Postal Service employee, sought continued compensation after OWCP ended benefits for accepted neck and back strains. An earlier Board decision had upheld that termination, shifting the burden to her to show later injury-related disability. New reports from her treating doctors…
J.K. and U.S. Postal Service, Post Office, Eatontown, NJ
J.K. (ECAB 12-1830): New hip report requires merit review
J.K., a Postal Service express clerk, had an accepted right hip sprain and later claimed that a recurrence, avascular necrosis and hip replacement were related to it. OWCP denied the recurrence and then rejected her request for further merit review. Her surgeon’s new report described earlier…
M.F. and U.S. Postal Service, Pen Argyl Post Office, Pen Argyl, PA
M.F. (ECAB 13-615): Reconsideration denial upheld
M.F., a Postal Service city carrier, had an accepted left ankle sprain and later sought benefits for a claimed recurrence and proposed surgery. OWCP denied the recurrence and subsequent requests for modification. In her next reconsideration request, she submitted two x-ray films. The Board found…
L.A. and U.S. Postal Service, Post Office, Albany, NY
L.A. (ECAB 13-536): Thumb and carpal tunnel claim files ordered combined
L.A., a Postal Service employee, sought benefits for a bilateral trigger thumb condition after an earlier accepted bilateral carpal tunnel claim. OWCP denied the thumb claim while referring to medical records from the earlier case. The Board did not have that earlier file and could not fairly…
A.W. and U.S. Postal Service, Processing & Distribution Center, Chattanooga, TN
A.W. (ECAB 13-435): Shoulder and elbow claim denial upheld
A.W., a Postal Service processing clerk, reported right shoulder and left elbow pain after pulling down a mail tray and trying to catch it. OWCP accepted that the incident occurred but found medical causation unproved. The Board found that one doctor offered no causal opinion and another was…
G.K. and U.S. Postal Service, Post Office, Dumont, NJ
G.K. (ECAB 13-382): Missing hearing transcript requires remand
G.K., a Postal Service employee, appealed OWCP’s refusal to reconsider his claim. The case record sent to the Board contained documents referring to a September 2011 teleconference hearing, but lacked its transcript. The Board found that the missing testimony prevented informed review of OWCP’s…
L.J. and U.S. Postal Service, Post Office, New York, NY
L.J. (ECAB 13-339): Foot injury claim denial upheld
L.J., a Postal Service retail and distribution clerk, said scanners fell onto her left foot at work. Her supervisor disputed the account, noting that L.J. worked for two more days without complaint and did not report the incident until a week later. The Board found these gaps unexplained and held…
K.M. and U.S. Postal Service, Post Office, Honolulu, HI
K.M. (ECAB 13-305): Shoulder injury claim denial upheld
K.M., a Postal Service letter carrier, reported left shoulder pain while lifting newspaper bundles into a postal truck. OWCP accepted that the incident happened. His orthopedic surgeon diagnosed a rotator cuff tear and set work restrictions, but did not explain the medical link between lifting the…
P.P. and Department of Veterans Affairs, Veterans Administration Medical Center, Bedford, MA
P.P. (ECAB 12-1917): New knee diagnosis requires merit review
P.P., a Veterans Affairs program support clerk, said she injured her right knee while intervening in a dispute between residents. OWCP accepted the incident but denied the claim because the initial diagnosis came from a nurse practitioner rather than a physician. P.P. then submitted a…
G.C. and U.S. Postal Service, Main Post Office, Lakeland, FL
G.C. (ECAB 12-1842): Emotional condition claim denial upheld
G.C., a Postal Service sales and service associate, claimed an emotional condition after a dispute with managers over lunch, wash-up time and use of a restroom. She also alleged abusive treatment. The Board found that the evidence did not establish the alleged verbal abuse or that denial of her…
R.H. and U.S. Postal Service, Post Office, Ashland, KY
R.H. (ECAB 12-1384): Termination of wage and medical benefits upheld
R.H., a Postal Service employee with accepted shoulder and back conditions, received compensation after OWCP reopened his claim. Conflicting medical opinions led OWCP to obtain an impartial orthopedic examination. R.H. challenged the selection process, but the Board found that the appointment…
Hayward Baker, Inc.
Drill pinch-point and training items affirmed
Hayward Baker employees loaded steel casing onto a drill shaft while installing soil nails for a retaining wall. When a casing was difficult to align, the shaft moved as an employee handled it, catching and crushing his hand at an unguarded pinch point. The judge found that moving the shaft while…
AIC Marianas, Inc.
Raised bucket and worn tire items affirmed
AIC Marianas replaced a water line beside a roadway in Saipan. A parked backhoe had its rear bucket suspended above the ground without adequate blocking, leaving nearby workers exposed if the hydraulic system failed. A dump truck also had an outer rear tire with no tread and visible cracking, and…
Pinnacle Mining Company, LLC
Final assessment reopened after counsel's assistant missed deadline
Pinnacle Mining asked the Commission to reopen a penalty assessment that became final after its counsel's assistant missed the contest deadline. The company said the assistant had health problems and the office was undergoing other personnel changes. Pinnacle mistakenly paid the penalty before…
Secretary of Labor v. D & S Mining and Exploration
Unopposed requests reopened two final assessments
D & S Mining and Exploration asked the Commission to reopen two penalty assessments that had become final orders after the company did not timely contest them. The Secretary did not oppose either request, and the public order does not state why the deadlines were missed. In the interests of…
Bay Materials, LLC
Final assessment reopened with warning to counsel
Bay Materials asked the Commission to reopen a penalty assessment that became final after its counsel received the assessment but took no action for almost two months. The company was a small operator with limited experience in the assessment process, and the Secretary did not oppose reopening…
Utility Services Co., Inc.
Final assessment reopened after operator reported nonreceipt
Utility Services asked the Commission to reopen a penalty assessment that became final when the company did not contest it within 30 days. The company said it never received the proposed assessment and learned of it only after MSHA sent a delinquency notice. The Secretary did not oppose reopening…
Joe Estis, employed by Chemical Lime Company of Alabama, LLC
Section 110(c) reopening request dismissed as moot
Joe Estis and Chemical Lime Company of Alabama asked the Commission to reopen an individual penalty assessment that became final after Estis did not timely contest it. Counsel stated that MSHA sent the assessment to an address where Estis no longer lived, and the Secretary did not oppose reopening…
McCoy Elkhorn Coal Corporation
Timely contest confirmed and case remanded
MSHA's records showed that McCoy Elkhorn Coal's penalty assessment had become a final order, but the operator said it had filed a timely contest. McCoy supplied a copy of the contest form bearing MSHA's receipt stamp, and the Secretary confirmed that MSHA received it on time. The Commission found…
The Doe Run Company
Late contest reopened after internal mailing lapse
The Doe Run Company asked the Commission to reopen a penalty assessment that became final when its contest was not mailed on time. The company's safety director reviewed the assessment within the contest period but, because of increased responsibilities, failed to mail the contest. She discovered…
Magruder Limestone Company, Inc.
Lockout order vacated and fall-protection citation reduced
An MSHA inspector saw a Magruder Limestone plant operator standing about ten feet above the ground on an inclined conveyor while clearing a rock jam without fall protection or lockout procedures. The parties stipulated that both cited conditions were violations, but Judge Thomas P. McCarthy set…
S.H. and Department of the Army, Fort George G. Meade, MD
S.H. (ECAB 13-744): Termination of hand and arm benefits upheld
S.H., an Army secretary, received compensation for accepted hand, elbow and carpal tunnel conditions. Earlier attempts to terminate her benefits had been reversed because of unresolved medical conflicts or problems with specialist selection. OWCP then obtained a new impartial orthopedic examination…
R.Y. and U.S. Postal Service, Post Office, Palatine, IL
R.Y. (ECAB 13-735): Snowdrift fall claim denial upheld
R.Y., a Postal Service carrier, said he fell while crossing a snowdrift on his route and later developed severe leg and back symptoms. OWCP accepted that the February 3, 2011 fall occurred. His surgeon attributed some symptoms to a fall in January 2011 and discussed degenerative spinal disease, but…
D.G. and Department of Veterans Affairs, Hudson Valley Health Care Service, Castle Point, NY
D.G. (ECAB 13-612): Back disability recurrence denial upheld
D.G., a Veterans Affairs nurse, sustained an accepted lumbar sprain while moving a patient in October 2011 and returned to work. She later stopped work with a herniated disc and claimed a recurrence of disability from the earlier injury. Her surgeon described the disc and surgery and stated that…
G.P. and U.S. Customs & Border Protection, Field Operations Academy, Glynco, GA
G.P. (ECAB 13-407): Training fall injury claim denial upheld
G.P., a Customs and Border Protection officer, fell during required defensive tactics training and sought benefits for left shoulder and arm symptoms. OWCP accepted the fall but disputed medical causation. One doctor checked a form indicating a work connection and later discussed vigorous training…
V.N. and Department of Veterans Affairs, Veterans Administration Medical Center, Fayetteville, NC
V.N. (ECAB 13-50): Specialist travel expense denial sent back for evidence
V.N., a Veterans Affairs patient services assistant with accepted carpal tunnel conditions, was referred to a hand specialist about 102 miles from her home. OWCP paid wage-loss compensation for treatment visits but denied the travel expenses, saying closer specialists were available. V.N. disputed…
R.F. and U.S. Postal Service, Processing & Distribution Center, Little Rock, AR
R.F. (ECAB 12-1816): Union activity injury claim sent back for fact finding
R.F., a Postal Service mail handler and union steward, reported stress after an alleged altercation with a coworker about a union election. OWCP denied the claim as a private union dispute outside the performance of duty. The Board held that authorized union representational functions can fall…
P.K. and Department of Agriculture, Forest Service, Albuquerque, NM
P.K. (ECAB 13-566): Field assignment illness claim denial upheld
P.K., a Forest Service forestry technician, reported painful urination and blood in his urine during a fire assignment. He attributed the symptoms to varied food and water supplies in the field. OWCP accepted his reported work duties and diagnosis of hematuria, but denied the claim for lack of…
B.K. and U.S. Postal Service, Post Office, Colorado Springs, CO
B.K. (ECAB 13-481): Leg numbness injury claim denial upheld
B.K., a Postal Service city carrier, reported left leg numbness that began in July 2012. She said she might have twisted or lifted incorrectly but could not identify how an injury happened. OWCP asked for a description of the work event and a physician’s medical opinion, but received neither. The…
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.