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.
B.C. and U.S. Postal Service, Post Office, Philadelphia, PA
B.C. (ECAB 11-1043): Sixth edition schedule award challenge rejected
B.C. argued that OWCP should have applied the fifth edition of the A.M.A. Guides to her schedule award rather than the sixth. The Board found no vested right to use the earlier edition and held that the edition effective when OWCP decided the award controlled. It affirmed.
J.C. and U.S. Postal Service, Post Office, Buffalo, NY
J.C. (ECAB 11-1038): Reconsideration denial set aside over overlooked report
J.C. sought reconsideration of a recurrence claim denial. OWCP said his submission was repetitive, but did not address a treating physician report it received before the decision. The Board set aside the refusal and directed OWCP to consider that timely medical evidence.
M.C. and U.S. Postal Service, Processing & Delivery Center, City of Industry, CA
M.C. (ECAB 11-0822): Total disability recurrence denied
M.C. sought compensation for a recurrence of total disability beginning in April 2010 after an accepted postal work injury. The Board found that the medical evidence did not establish that her later inability to work was caused by the accepted condition. It affirmed OWCP’s denial.
M.G. and Department of Justice, Bureau of Alcohol, Tobacco & Firearms, Mount Laurel, NJ
M.G. (ECAB 11-0806): Schedule award pay rate change reversed
M.G. challenged OWCP’s change to the pay rate used for a schedule award after an accepted right knee injury. The Board found that the revised rate was improper on the case record and reversed OWCP’s decision.
K.J. and Department of Labor, Office of the Assistant Secretary for Administration & Management, Boston, MA
K.J. (ECAB 11-0571): Leave buyback compensation denied
K.J. sought compensation for disability from July through September 2006. The Board found that the employer had disallowed buyback of annual and sick leave, including leave advanced to her during the claimed period. It held that she could not receive wage-loss compensation for the period covered by…
D.B. and U.S. Postal Service, Post Office, St. Louis, MO
D.B. (ECAB 11-0463): Schedule award and recurrence returned for full record
D.B. appealed denials of a schedule award and disability recurrence after accepted shoulder injuries. The Board found that the appeal record was incomplete and contained conflicting accounts about whether she had continued in light duty work. It set aside both decisions and directed OWCP to…
M.B. and U.S. Postal Service, Post Office, Austin, TX
M.B. (ECAB 11-0272): Wage capacity modification denied
M.B. sought modification of a wage earning capacity determination made in March 2000. The Board found that the evidence before OWCP did not establish an error in the original decision or another ground for changing it. It affirmed OWCP’s refusal.
J.T. and Department of Veterans Affairs, Veterans Administration Medical Center, Richmond, VA
J.T. (ECAB 11-0233): Emotional condition claim returned for medical review
J.T. attributed an emotional condition to an unusually heavy workload and other workplace events. The Board found that the documented workload was a compensable work factor. Because OWCP had denied the claim without reviewing medical causation, it set aside the decision and returned the claim for…
American Federation of Government Employees, Local 405 (Union) and United States Department of Justice, Federal Bureau of Prisons, Federal Correctional Complex, Butner, North Carolina (Agency)
AFGE Local 405 and Butner prison complex (FLRA 0-AR-4793): Arbitration challenge denied
AFGE Local 405 challenged an arbitrator's dismissal of a grievance involving the Butner federal prison complex. The arbitrator had found the grievance outside arbitration under a statutory exception and, independently, untimely under the parties' agreement. In an abbreviated decision, the Authority…
American Federation of Government Employees, Local 1399 (Union) and United States Department of the Navy, Command Navy Region Southwest, March Air Reserve Base, California (Agency)
AFGE Local 1399 and Navy (FLRA 0-AR-4777): Training time denial upheld
A Navy command denied official time for the union's new treasurer to attend financial officers' training. An arbitrator found that the training was not internal union business, but the parties' agreement said the agency may authorize time for training. She concluded that approval was discretionary…
United States Department of Agriculture, Farm Service Agency, St. Louis, Missouri (Agency) and American Federation of Government Employees, Local 3354 (Union)
Farm Service Agency and AFGE Local 3354 (FLRA 0-AR-4758): Official time award upheld
The Farm Service Agency denied union representatives official time to attend a meeting advertised as an expanded membership event. An arbitrator found that the meeting included discussion of grievances, working conditions, and proposed contract changes, and awarded the requested time. The agency…
United States Department of Transportation, Federal Aviation Administration (Agency) and Professional Aviation Safety Specialists (Union)
FAA and aviation safety specialists (FLRA 0-AR-4713): Overtime remedy narrowed
The FAA underpaid overtime by leaving holiday premium pay and cost-of-living allowances out of its calculations. An arbitrator awarded several years of unpaid overtime, liquidated damages, and interest. The Authority held that the Fair Labor Standards Act's three-year recovery period ran backward…
Adelman Sand & Gravel, Inc.
Timely answer prevents default
Adelman Sand & Gravel did not initially answer the Secretary's penalty petition, so the Chief Judge issued a show-cause order that would become a default after 30 days. Adelman produced a certified-mail receipt showing that the Commission's Docket Office received its answer within that period. The…
Lakeview Rock Products
Blasting and highwall violations yield $3,000 penalty
Lakeview Rock Products operates a sand and gravel mine where flyrock from a blast traveled about 600 to 700 yards, penetrated a nearby home's roof and attic, and entered the living room. Judge William B. Moran found that the blaster failed to account for the nearby residences and that the occupants…
Matter of J. R. VELASQUEZ
Authenticated conviction records are required
The Board reviewed the removal case of a Salvadoran lawful permanent resident charged with multiple crimes involving moral turpitude. It held that the records listed in the Immigration and Nationality Act and the regulations are admissible to prove a conviction, while other probative evidence may…
J.L. and U.S. Postal Service, Post Office, Merrick, NY
J.L. (ECAB 11-1511): Benefit termination reversed for medical conflict
J.L. challenged OWCP’s termination of wage loss and medical benefits after an accepted injury. The Board found an unresolved conflict between her physician and OWCP’s second opinion doctor on continuing residuals. It reversed the termination and directed payment of appropriate compensation; the…
S.P. and Department of Veterans Affairs, Veterans Administration Medical Center, Fort Smith, AR
S.P. (ECAB 11-1323): Compensation and medical termination upheld
S.P. received compensation after an accepted injury from a workplace fall. OWCP terminated wage loss and medical benefits in September 2010. The Board found that the medical evidence supported the termination and affirmed OWCP’s decision.
A.C. and U.S. Postal Service, Post Office, Cincinnati, OH
A.C. (ECAB 11-1289): Knee injury benefit termination upheld
A.C. received benefits for an accepted left knee condition attributed to postal work. OWCP ended compensation and medical benefits in November 2010. The Board found the medical evidence sufficient to show the accepted injury effects had ceased and affirmed the termination.
B.R. and Department of Homeland Security, Transportation Security Administration, Vandalia, OH
B.R. (ECAB 11-1223): Emotional condition claim denied
B.R. attributed an emotional condition to events while working for the Transportation Security Administration. The Board found that the asserted events did not establish a compensable work factor on the record. It affirmed OWCP’s denial.
C.C. and U.S. Postal Service, Post Office, Coppell, TX
C.C. (ECAB 11-1023): January disability period denied
C.C. sought compensation for disability from January 3 through 21, 2011 after an accepted November 2010 work injury. The Board found that the medical evidence did not establish disability during those dates caused by the accepted condition. It affirmed OWCP’s denial.
E.T. and U.S. Postal Service, Processing & Distribution Facility, Sioux City, IA
E.T. (ECAB 11-0927): Back disability recurrence claim denied
E.T., a postal clerk with an accepted lumbar disc condition, sought wage loss compensation after leaving a modified duty position in August 2007. She argued that her condition prevented work and that the Postal Service had withdrawn suitable light duty. The Board found that her physician's reports…
M.N. and Defense Commissary Agency, Maxwell Air Force Base, AL
M.N. (ECAB 11-0817): Intermittent wage loss claim and reconsideration refusal affirmed
M.N., a commissary cashier with an accepted lumbar sprain, sought compensation for intermittent absences in 2008 and 2009. Her physicians documented back pain and work absences, but the Board found that their reports did not explain how the accepted sprain caused disability on the specific dates…
J.V. and U.S. Postal Service, Post Office, Pittsburgh, PA
J.V. (ECAB 11-0764): Disability recurrence and disc condition claims denied
J.V., a postal manager, injured his neck and shoulders in a 2005 work vehicle collision and later had an accepted right knee meniscus tear. After working limited duty, he stopped work in November 2007 and claimed a recurrence of disability. He also sought to link cervical and lumbar disc…
D.S. and U.S. Postal Service, Dominick V. Daniels Processing & Distribution Center, Kearney, NJ
D.S. (ECAB 11-1577): Accepted cage door incident did not establish a knee injury
D.S., a postal expediter, reported that a mail cage door struck his left knee at work. OWCP accepted that the incident occurred, but denied his claim for lack of medical evidence connecting it to his diagnosed knee conditions. An orthopedic surgeon diagnosed internal derangement and meniscus tears…
J.P. and Department of Health & Human Services, Social Security Administration, Chicago Field Offices, Chicago, IL
J.P. (ECAB 11-1507): Mold exposure did not establish the claimed illness
J.P., a Social Security Administration employee, claimed that workplace mold caused respiratory symptoms and other health problems. OWCP accepted that she had been exposed to mold but denied the claim because the record lacked a firm medical diagnosis and a physician's opinion connecting her…
R.A. and U.S. Postal Service, Post Office, San Diego, CA
R.A. (ECAB 11-1435): Neck condition was temporarily aggravated by work
R.A., a postal employee, had accepted neck injuries and claimed that her later work duties and a December 2004 incident permanently worsened her cervical disc disease. Her treating physician attributed continuing symptoms and disc findings to the work, while a second opinion physician found that…
C.P. and U.S. Postal Service, Post Office, Old Greenwich, CT
C.P. (ECAB 11-1432): Fall on public sidewalk was outside postal employment
C.P., a postal carrier, broke his ankle after slipping on a snowy public sidewalk while walking to work. The sidewalk was about 60 yards from the post office and was neither owned nor operated by the Postal Service. The Board found that he had not begun work and that the fall occurred outside the…
W.F. and U.S. Postal Service, Post Office, Chester, PA
W.F. (ECAB 11-1258): Full-duty medical release supported ending wage benefits
W.F., a postal carrier, received monetary compensation after an accepted back and neck injury kept her from work. OWCP ended those payments after her longtime treating physician reviewed surveillance footage and released her to full-duty work. She argued that his first duty report understated the…
D.N. and Department of the Air Force, Edwards Air Force Base, CA
D.N. (ECAB 11-0906): No ratable leg impairment shown for schedule award
D.N., an Air Force firefighter, sought a schedule award after an accepted low back injury and surgery. Two physicians rated his spine or whole-person impairment, but FECA does not pay a schedule award for the back or body as a whole. A third physician rated both legs at 13 percent without examining…
J.J. and U.S. Postal Service, Post Office, Tacoma, WA
J.J. (ECAB 11-0752): Five percent arm impairment award affirmed
J.J., a postal carrier, injured his left shoulder while making deliveries and later underwent rotator cuff surgery. OWCP granted a schedule award for five percent impairment of his left arm, payable over 15.6 weeks. J.J. sought a larger award, pointing to a previous award after a similar operation…
M.S. and Department of Veterans Affairs, Veterans Administration Medical Center, North Chicago, IL
M.S. (ECAB 11-0595): Board reduced supported leg impairment to 20 percent
M.S., a Department of Veterans Affairs food service worker, previously received a schedule award for 20 percent left leg impairment after a knee injury. OWCP later added two percent for a partial meniscectomy, bringing its stated impairment rating to 22 percent, and denied her request for…
C.M. and U.S. Postal Service, Post Office, Hillsboro, OH
C.M. (ECAB 11-0026): Recurrence denial affirmed; additional conditions returned to OWCP
C.M., a postal carrier, claimed a recurrence of disability from an accepted 2000 back injury after she stopped working in October 2009. Her physician attributed increased problems in part to a fall on ice in February 2009, but did not explain a spontaneous change in the accepted condition causing…
Wolf Run Mining Co.
Summary motions denied in flagrant-violation dispute
MSHA proposed a $142,900 flagrant penalty for extensive combustible coal and coal-dust accumulations at Wolf Run's Sentinel Mine. The parties agreed that the section 75.400 violation occurred, involved high negligence, was S&S and unwarrantable, and could reasonably cause permanently disabling…
George Reed, Inc.
Timely answer prevents default
George Reed did not initially answer the Secretary's penalty petition, prompting a show-cause order that would become a default after 30 days. The company produced a certified-mail receipt showing that the Commission's Docket Office received its answer on time. The Secretary did not oppose…
North Montgomery Materials, LLC
Default vacated and penalty case reopened
North Montgomery Materials did not answer a show-cause order, causing a default to become effective in its penalty case. The company said it had timely answered the Secretary's penalty petition and never received the show-cause order. The Secretary did not oppose reopening and confirmed that MSHA's…
James River Coal Service Company
Default vacated and penalty case reopened
James River Coal Service did not answer a show-cause order, causing a default to become effective in its penalty case. The company said it never received the Secretary's penalty petition, while the Secretary reported that MSHA's records contained a timely answer that apparently had not been sent to…
Bachmann Sand & Gravel
Equipment and storage violations yield $1,186 penalty
Bachmann Sand & Gravel operates a small South Dakota mine where county employees used the operator's loader when no mine employee was present. Judge Margaret A. Miller affirmed violations involving damaged conveyor guards, an inoperative backup alarm, a parking brake that would not hold, dry…
E.R. and U.S. Postal Service, Post Office, Newark, NJ
E.R. (ECAB 11-1656): Reconsideration request did not reopen injury claim
E.R., a postal carrier, claimed that lifting and pushing heavy objects at work caused neck and back conditions. OWCP denied the claim in 2009, and he later sought reconsideration with medical reports. The Board reviewed only OWCP's refusal to reopen because the earlier merits decision was outside…
R.W. and General Services Administration, Washington, DC
R.W. (ECAB 11-1519): Knee evidence did not prove disability recurrence
R.W., a General Services Administration contract specialist, had an accepted right knee and trunk injury after falling on stairs in 2005. She stopped working in May 2010 and claimed a recurrence of disability as her knee problems worsened. Her physicians described worsening knee symptoms and…
M.N. and U.S. Postal Service, Post Office, Oklahoma City, OK
M.N. (ECAB 11-1317): Late reconsideration request did not show clear error
M.N., a postal carrier, claimed that her work duties contributed to a right foot condition. OWCP denied the claim in January 2008, and she later sought reconsideration. The Board reviewed OWCP's November 2010 refusal to reopen the claim, not the original denial's merits. It found her August 2009…
E.S. and Department of the Treasury, Internal Revenue Service, Kansas City, MO
E.S. (ECAB 11-1178): Workplace exposure claim lacked supporting details
E.S., an Internal Revenue Service employee, claimed that contaminated water and airborne substances at work caused a thyroid condition. Her medical records documented a multinodular goiter, but she gave no specific account of where or when the exposure occurred or what substances were involved…
C.V. and U.S. Postal Service, Post Office, Macon, MO
C.V. (ECAB 11-1177): Three percent arm impairment rating upheld
C.V., a postal carrier, fractured her right elbow in a fall at work and received a schedule award based on three percent permanent impairment of her right arm. She sought a higher rating, relying on doctors who assessed eight or ten percent. The Board found the ten percent opinion did not explain…
G.M. and Department of the Army, Tobyhanna Army Depot, Tobyhanna, PA
G.M. (ECAB 11-1152): Medical reports did not establish disability recurrence
G.M., an Army depot electronics worker, had accepted lumbar injuries after lifting a locker at work and later underwent back surgery. He returned to full duty in August 2010, then claimed a recurrence of total disability beginning in September. His doctors documented pain and work restrictions, but…
O.G. and Department of Justice, Bureau of Prisons, Federal Detention Center, Miami, FL
O.G. (ECAB 11-1112): Overpayment confirmed, amount and collection rate remanded
O.G., a Bureau of Prisons employee, received workers' compensation calculated from a weekly pay rate higher than the rate supported by his personnel record. The Board agreed an overpayment occurred and upheld OWCP's denial of waiver, finding that his resources exceeded the applicable limit and he…
B.S. and Department of Homeland Security, Federal Emergency Management Agency, Emergency Preparedness and Response, Alexandria, VA
B.S. (ECAB 11-0890): General clerk work supported wage capacity reduction
B.S., a Federal Emergency Management Agency disaster assistance worker, injured his left index finger and developed an infection after a splinter entered it at work. OWCP later reduced his wage-loss benefits based on the earnings available from a general clerk position. He argued that work with…
M.J. and U.S. Postal Service, Post Office, St. Louis, MO
M.J. (ECAB 11-0765): Prior leg impairment awards were not increased
M.J., a postal worker, had already received schedule awards for 11 percent permanent impairment of each leg. In an earlier appeal, the Board directed OWCP to obtain a medical assessment of whether sensory loss or pain warranted more. A new examiner found two percent sensory impairment in each leg…
United States Department of the Interior, Bureau of Land Management, Nevada State Office and National Federation of Federal Employees, Federal District 1, Locals 2174 and 2152
BLM Nevada and NFFE locals (FLRA SF-RP-11-0035): Union affiliation change upheld
Members of NFFE Local 2174 voted to change their affiliation to Local 2152, and a regional director amended the union's certification. The Bureau of Land Management challenged the vote, saying that a Reno member had not received notice and that no nonprofessional employees had voted. The Authority…
Southern Wood Piedmont Company and Rayonier Inc.
In re Southern Wood Piedmont Company and Rayonier Inc. (EAB RCRA (3008) 11-04(C)): Consent Agreement ratified
Southern Wood Piedmont Company and Rayonier Inc. were respondents in an RCRA penalty matter. The Board incorporated and ratified the Consent Agreement under 40 C.F.R. § 22.18(b) and section 3008(a), 42 U.S.C. § 6928(a). It ordered both respondents to comply with all terms of the agreement effective…
Conshor Mining, LLC
Flagrant-violation question certified for review
The Secretary sought enhanced flagrant penalties for three roof-control violations based on Conshor Mining's history of similar unwarrantable violations, even though the current orders alleged high negligence rather than reckless conduct. Judge Jerold Feldman had ruled that violation history alone…
Matter of U. SINGH
Stalking conviction qualifies as aggravated felony
The Board reviewed the Department of Homeland Security's appeal from a waiver grant to an Indian lawful permanent resident convicted in California of felony stalking. It held that a federal appellate decision reversing a Board precedent is binding only within that circuit, so Matter of Malta…
B.H. and Department of Agriculture, FSIS Inspection Operations Program, Noel, MO
B.H. (ECAB 11-1539): Medical reports did not establish chlorine exposure injury
B.H., an Agriculture Department employee, claimed that chlorine vapors at work caused respiratory and throat problems. OWCP accepted that the exposure occurred but denied the injury claim. One doctor diagnosed laryngitis and linked it to the exposure without explaining how the exposure caused the…
M.J. and U.S. House of Representatives, Congressional Office, Lakewood, OH
M.J. (ECAB 11-1488): Medical bill denial lacked findings and reasons
M.J., a congressional staffer, sought payment of a $243.25 bill for treatment after a fall in a work parking lot. OWCP denied payment in a brief letter stating that her injury claim had been denied. The Board found that OWCP had earlier accepted the claim under a policy allowing limited medical…
L.K. and U.S. Postal Service, Post Office, Sequim, WA
L.K. (ECAB 11-1393): Benefits termination reversed over unexamined left arm limits
L.K., a postal carrier with an accepted right shoulder and upper arm injury, declined a modified job offer. OWCP terminated her benefits after finding the position suitable. Her physician had approved the job for her right arm but warned that a separate left shoulder condition might prevent the…
B.S. and U.S. Postal Service, Post Office, Spartanburg, SC
B.S. (ECAB 11-1292): Unresolved medical conflict required further review
B.S., a postal employee with accepted neck and shoulder conditions, worked in a modified position that OWCP used to determine her wage-earning capacity. She later said her conditions had worsened and sought a change to that determination. Her treating physicians and OWCP's second opinion physician…
J.O. and Department of Veterans Affairs, Veterans Health Administration, Fort Dodge, KS
J.O. (ECAB 11-1269): Mold exposure claim denied for lack of medical proof
J.O., a patient services assistant at a veterans health facility, claimed that mold exposure at work caused respiratory and other symptoms. Her employer confirmed the exposure, and OWCP accepted that it occurred. The Board found no physician's report explaining how the exposure caused or aggravated…
J.C. and U.S. Postal Service, North Quincy Post Office, Quincy, MA
J.C. (ECAB 11-1189): Termination upheld; later disability question remanded
J.C., a postal letter carrier, had accepted neck injuries and later lost his light-duty position. OWCP terminated his compensation and medical benefits after its second-opinion physician found that the accepted conditions had resolved. The Board upheld that termination because J.C.'s earlier…
B.M. and U.S. Postal Service, Post Office, St. Louis, MO
B.M. (ECAB 11-1094): Conflicting medical opinions require a new claim decision
B.M., a postal carrier, attributed degenerative neck and shoulder conditions to years of carrying a mailbag and other delivery work. OWCP denied his occupational disease claim after a second-opinion physician attributed the conditions to age, weight and other causes. B.M.'s treating physician gave…
D.W. and U.S. Postal Service, Post Office, Milwaukee, WI
D.W. (ECAB 11-1045): Wage-capacity decision reversed for premature calculation
D.W., a postal letter carrier with an accepted foot condition, returned to a modified carrier technician job. OWCP used his pay in that job to determine his wage-earning capacity in November 2003. When hours in the modified assignment were later withdrawn, he sought to change the determination, but…
M.S. and U.S. Postal Service, Post Office, Livonia, MI
M.S. (ECAB 11-0918): Continuing disability claim lacked new medical evidence
M.S., a postal carrier, had an accepted claim for acute stress disorder and post-traumatic stress disorder following a workplace assault. OWCP later ended his medical benefits after a psychiatrist reported that the accepted conditions had resolved. The Board could review only OWCP's August 2010…
Vindex Energy Corporation
Screen citation settled for $3,996
The Secretary and Vindex Energy proposed settling a citation involving a portable mechanical screen that was moved at least once per shift. They agreed that the machine's extremely slow movement supported reducing the likelihood of injury from highly likely to reasonably likely. That change reduced…
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.