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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G.A. and U.S. Postal Service, Post Office, Carol Stream, IL
G.A. (ECAB 11-328): Denial of further training allowance upheld
G.A., a postal distribution clerk with an accepted post-traumatic stress disorder claim, entered a vocational rehabilitation program at a college. Years later, he sought a further maintenance allowance for the time he attended classes from 1997 to 1998. OWCP had paid his books and supplies and…
M.S. and U.S. Postal Service, Post Office, Elmwood, NJ
M.S. (ECAB 11-257): Leg impairment claim sent for a new medical evaluation
M.S., a postal mail carrier, sought a schedule award for lasting impairment in both legs after accepted lower back conditions and surgery. Her physician and OWCP’s medical adviser disagreed about the impairment rating, so OWCP sent her to an impartial specialist. That specialist rated her spine…
Oxbow Mining, LLC
Post-hearing interrogatory answer excluded
After the hearing on a loose-rock citation, the Secretary sought to add Oxbow's interrogatory answer to challenge testimony about where rock fell when it was barred down. Judge Richard W. Manning denied the request because Oxbow had denied the related request for admission, so the fact was not…
Pension Benefit Guaranty Corporation (Agency) and Independent Union of Pension Employees for Democracy and Justice (Labor Organization/Petitioner) and Union of Pension Employees (Labor Organization/Incumbent)
PBGC union election (FLRA WA-RP-10-0070): E-mail campaign objections rejected
Pension Benefit Guaranty Corporation employees voted 194 to 138 to replace their incumbent union with the Independent Union of Pension Employees for Democracy and Justice. The incumbent union objected, saying the challenger's campaign e-mails and the agency's treatment of them unfairly affected the…
The American Coal Company
Nine violations and safeguards resolved for $99,440
MSHA litigated nine accumulation, methane-testing, electrical, roof-control, and diesel-equipment violations at American Coal's large Galatia Mine, while four safeguard citations were settled for $9,640. Judge Richard W. Manning affirmed an S&S feeder-accumulation violation but removed…
Austin Powder Company
Flyrock summary-decision motion denied
Austin Powder sought summary decision on ground-control citations and orders arising from blasting events in which flyrock allegedly struck nearby homes. It argued that flyrock alone did not violate the revised ground-control plan, that the plan no longer required presplitting, and that…
Bledsoe Coal Corporation
Lifeline order affirmed and accumulation citation vacated
MSHA charged Bledsoe Coal with six violations at Mine No. 4, and the parties settled four of them. Judge Gary Melick affirmed an order for failing to maintain a continuous directional lifeline in the secondary escapeway for at least five crosscuts. He found that violation significant and…
J.P. and Department of Veterans Affairs, Central Arkansas Health Care System, Little Rock, AR
J.P. (ECAB 11-1050): Off-site traffic injury claim denied
J.P., a Veterans Affairs nursing assistant, was in a traffic accident on a public street while traveling to a required meeting. She argued that the street and a nearby overflow parking lot should count as part of her workplace, particularly because an agency shuttle bus struck her vehicle. The…
R.L. and U.S. Postal Service, Post Office, Miami, FL
R.L. (ECAB 11-1018): Shoulder injury claim denied for lack of detail
R.L., a postal mail carrier, claimed that work activities caused pain in both shoulders. The Board found that he had not described the particular duties, circumstances, or timing of the claimed exposure in enough detail to establish what happened. He did not answer OWCP’s request for more facts…
G.B. and U.S. Postal Service, Post Office, Milwaukee, WI
G.B. (ECAB 11-1000): Twenty-five percent left leg award upheld
G.B., a postal rural carrier, injured his left leg and knee in a work-related vehicle accident and later had knee surgery. OWCP awarded him compensation for a 25 percent permanent impairment of his left leg. He sought a higher rating based on a 50 percent rating under Wisconsin standards and a 48…
T.L. and U.S. Postal Service, Post Office, Cleveland, OH
T.L. (ECAB 11-987): Knee injury claim denied for lack of medical proof
T.L., a postal custodian, felt pain in his right knee while walking to his vehicle during a work break. He claimed a traumatic injury, but the Board found that he did not explain a specific injury mechanism beyond experiencing pain while walking. The medical reports described pain and possible knee…
G.S. and Department of the Army, Anniston Army Depot, Anniston, AL
G.S. (ECAB 11-949): Extra wage loss for medical visit denied
G.S., an Army equipment repairer with an accepted sciatica claim, sought nine hours of wage-loss compensation for a day when he saw his physician. OWCP allowed four hours for the appointment but denied the other five. The Board explained that four hours is the usual allowance for a routine medical…
L.K. and U.S. Postal Service, Processing & Distribution Center, Fort Lauderdale, FL
L.K. (ECAB 11-768): Mail clerk’s occupational disease claim denied
L.K., a postal mail clerk, reported head, neck, back, and arm symptoms after repetitive work with mail processing machines. She filed notices calling the symptoms recurrences of earlier injuries. The Board agreed with OWCP that her account described new exposure to work activities, so the claim…
N.A. and Social Security Administration, Midwest Region, Chicago, IL
N.A. (ECAB 11-727): Emotional condition claim denied for lack of supported work factors
N.A., a Social Security Administration representative, claimed a work-related emotional condition arising from alleged harassment, discrimination, and management actions. The Board explained that personnel decisions can support a FECA claim when error or abuse is shown, and that alleged harassment…
J.D. and U.S. Postal Service, Post Office, Wilmington, DE
J.D. (ECAB 11-427): Five percent right arm impairment award upheld
J.D., a postal clerk, had accepted right carpal tunnel syndrome and received a schedule award for five percent right arm impairment. Her physician proposed a higher rating, including an additional rating for a shoulder condition. The Board accepted OWCP’s consultant’s calculation under the sixth…
S.C. and Department of the Navy, Puget Sound Naval Shipyard, Bremerton, WA
S.C. (ECAB 11-240): Back disability recurrence claim denied
S.C., a Navy shipyard instructor, returned to limited-duty work after an accepted back injury. He later stopped work for several weeks after back and leg symptoms returned while he was on vacation. The Board found no evidence that his limited-duty job had changed or become unavailable. His doctors…
Eutaw Construction Company, Inc.
Controlling-employer trench citation affirmed
Eutaw Construction was the general contractor for a sewer-line project where a subcontractor worked in a 14-foot-deep bore pit. The excavation was dug in unstable Type C soil, and its protective system had trench boxes several feet above the bottom, gaps, a damaged support, water seepage, erosion…
Oak Grove Resources, LLC
Flooded bleeder order and unwarrantable failure affirmed
Water and a roof fall made portions of Oak Grove's bleeder system impassable, preventing certified officials from examining 11 measuring points for about three weeks. The mine liberated more than one million cubic feet of methane daily, yet Oak Grove resumed longwall production while the bleeder's…
Emerald Coal Resources, LP
Coal-dust order upheld and $127,531 assessed
MSHA brought 28 alleged violations against Emerald Coal Resources at its Emerald Mine No. 1, and the parties resolved all but one through settlements or vacatur. Judge David F. Barbour upheld the remaining order under 30 C.F.R. § 75.400 after finding extensive dry coal dust along a shuttle-car…
Northern Filter Media, Inc.
Settlement denied for inadequate support
MSHA cited Northern Filter Media for three alleged violations after a miner was seriously injured when he became entangled in conveyor components. The Secretary proposed reducing a $52,500 guarding penalty to $10,000 and cutting two other penalties by about half, relying on the operator's account…
M.P. and U.S. Postal Service, Post Office, Chillicothe, OH
M.P. (ECAB 11-951): Emotional condition claim denial affirmed
M.P., a postal letter carrier, claimed that disciplinary actions and denied leave requests caused stress, depression, and hypertension. The Board found that these were personnel matters and that the evidence did not establish error or abuse by management in handling them. It said reinstatement…
P.S. and Department of Commerce, Census Bureau, Ludowici, GA
P.S. (ECAB 11-829): Reconsideration denials upheld
P.S., a Census Bureau employee, had claimed that moving boxes caused a back and spinal condition. OWCP denied the claim on the merits in July 2010, and she twice sought reconsideration. The Board found that both requests repeated medical records OWCP had already considered and offered no new legal…
R.B. and U.S. Postal Service, Post Office, El Paso, TX
R.B. (ECAB 11-772): Elbow condition claim denied for lack of medical explanation
R.B., a postal letter carrier, developed pain in both elbows and was diagnosed with lateral epicondylitis. His job involved repetitive arm use while casing and carrying mail. The Board found that his physician attributed the condition to the work but did not explain the medical process by which…
R.B. and U.S. Postal Service, Post Office, El Paso, TX
R.B. (ECAB 11-769): Emotional condition claim denial upheld
R.B., a postal employee, claimed depression and anxiety after a reassignment from a supervisory position to letter carrier work. He alleged that the reassignment violated an employment settlement and that managers discriminated against and harassed him. The Board found that a reassignment was a…
D.A. and Department of the Treasury, Internal Revenue Service, Cheektowaga, NY
D.A. (ECAB 11-736): Carpal tunnel claim denied for lack of medical explanation
D.A., an IRS customer service representative, attributed carpal tunnel syndrome to years of typing and repeated mouse use. OWCP accepted that she performed those tasks, but the Board found that her physicians did not explain how they caused or aggravated her condition. Some reports instead…
R.C. and Social Security Administration, Southeast Region, Atlanta, GA
R.C. (ECAB 11-700): Schedule award denied for lack of leg impairment
R.C., a Social Security Administration claims representative, had accepted lower back conditions and underwent authorized surgery. He sought a schedule award based on claimed lasting impairment in both legs. An OWCP referral specialist found no ratable leg impairment, while his treating surgeon…
J.D. and U.S. Postal Service, Post Office, Bolton, MO
J.D. (ECAB 11-587): Two percent left leg impairment award upheld
J.D., a postal carrier, injured his left knee at work and had surgery for a meniscus tear. OWCP awarded him a schedule award for two percent permanent impairment of his left leg. He sought a higher award based on medical ratings of five and 16 percent. The Board found the five percent opinion did…
C.O. and U.S. Postal Service, Processing & Distribution Center, Palatine, IL
C.O. (ECAB 11-562): Reconsideration denial in wage capacity dispute upheld
C.O., a postal processing clerk with accepted shoulder conditions, challenged a wage-earning capacity determination after claiming new disability. OWCP denied modification, and she sought reconsideration. The Board found that her new medical forms addressed her condition in late 2010 but did not…
T.F. and U.S. Postal Service, Sun Coast Performance Cluster, Tampa, FL
T.F. (ECAB 11-319): Injury claim denial upheld after new medical report
T.F., a postal rural carrier, reported right leg and back symptoms after twisting while getting out of her vehicle on a mail route. OWCP accepted that the incident occurred but denied the injury claim because the medical evidence did not establish that it caused her conditions. After an earlier…
L.S. and U.S. Postal Service, Post Office, Houston, TX
L.S. (ECAB 11-302): Late reconsideration request denied
L.S., a postal custodian with an accepted shoulder injury, lost wage-loss benefits in 2003 after OWCP found he had refused suitable work. He requested reconsideration in 2010, arguing that OWCP had overlooked other medical conditions when deciding whether he could do the offered job. The Board…
Sand Cut Properties, LLC.
Willful excavation violations affirmed
Sand Cut Properties sent an employee into an excavation that was 6 to 9 feet deep, accumulating water, and repeatedly collapsing in unstable soil. A roughly 15-foot-high spoil pile overhung the edge, and the owner directed the employee to attach a sling to a concrete structure before the collapsing…
Matter of Luis Manuel GUERRERO
Solicitation of violent assault is an aggravated felony
The Board reviewed the appeal of a Dominican lawful permanent resident convicted of soliciting another person to commit assault with a dangerous weapon under Rhode Island law. It held that solicitation of a violent felony is itself a crime of violence under 18 U.S.C. § 16(b) when the intended…
C.D. and U.S. Postal Service, Post Office, Philadelphia, PA
C.D. (ECAB 11-1095): Compensation overpayment and repayment upheld
C.D., a postal clerk receiving disability compensation for an accepted shoulder injury, was paid at the higher rate for employees with a dependent spouse while she and her husband lived apart. OWCP calculated an overpayment of $2,942.74 after accounting for a separate pay-rate error. Although OWCP…
Y.S. and U.S. Postal Service, Post Office, New Orleans, LA
Y.S. (ECAB 11-997): Overpayment finding reversed for inadequate calculation
Y.S., a postal employee receiving disability compensation, also worked as a schoolteacher in the private sector. OWCP found a $2,933.12 overpayment but did not explain how it calculated the amount she remained entitled to receive after starting that job. The Board found that OWCP had still not made…
J.O. and U.S. Postal Service, Post Office, Birmingham, AL
J.O. (ECAB 11-956): Carpal tunnel claim filed too late
J.O., a retired postal mail handler, filed a carpal tunnel claim in August 2010. The Board found that he had been diagnosed in 2004 and knew or should have known by 2006 that his work activities worsened the condition. Because he continued the same work until retiring in October 2006, the…
L.N. and Department of Justice, U.S. Marshals Service, Alexandria, VA
L.N. (ECAB 11-936): Deputy marshal’s knee condition claim denied
L.N., a deputy marshal, claimed that years of physical work and required fitness activities caused a torn left meniscus and degenerative knee changes. OWCP accepted that his duties included extensive running and other physical tasks. The Board found that his surgeon attributed the condition to…
R.F. and U.S. Postal Service, Post Office, Macon, GA
R.F. (ECAB 11-931): Left knee impairment award sent back for clarification
R.F., a postal letter carrier, received a schedule award for a seven percent impairment of his left leg after an accepted knee condition. The examining surgeon selected a tibial plateau fracture as the basis for that rating, but did not explain why it best represented the impairment. The Board also…
R.F. and Department of Veterans Affairs, Veterans Health Administration, San Diego, CA
R.F. (ECAB 11-908): Additional thumb conditions denied; hearing request found abandoned
R.F., a Veterans Affairs nurse, had an accepted left thumb sprain after a fall at work and sought to add arthritis and trigger thumb to the claim. The Board found that the medical reports did not give a definite, reasoned explanation linking those additional conditions to the fall. R.F. also…
H.P. and U.S. Postal Service, Post Office, Los Angeles, CA
H.P. (ECAB 11-894): Schedule award denied for lack of permanent impairment
H.P., a postal custodian, had accepted neck and lower back conditions from heavy lifting and pulling. He sought a schedule award for permanent impairment linked to those conditions. OWCP’s medical adviser found no ratable impairment in his arms or legs based on the examination findings in the file…
M.G. and U.S. Postal Service, Post Office, Orlando, FL
M.G. (ECAB 11-882): Termination of neck injury benefits upheld
M.G., a postal carrier, had received benefits for an accepted neck strain. A prior Board decision found a medical disagreement about whether effects of the work injury continued. OWCP first sought an impartial opinion, then obtained another when the initial specialist did not clarify whether the…
A.H. and U.S. Postal Service, Post Office, DeForest, WI
A.H. (ECAB 11-828): Hip impairment award sent back for a new rating
A.H., a postal rural carrier, fractured his right hip after slipping on ice while carrying mail. OWCP gave him a schedule award for 31 percent impairment of his right leg, calculated from lost hip motion. The Board held that the sixth edition of the impairment guide called for a diagnosis-based…
S.B. and Department of Veterans Affairs, Northport Veterans Hospital, Northport, NY
S.B. (ECAB 11-514 and 11-653): Wage capacity ruling upheld, benefits termination reversed
S.B., a former respiratory therapist at a veterans hospital, received compensation for accepted back and neck injuries. She challenged a wage-earning capacity ruling based on a telephone solicitor position and a later termination for refusing a medical support assistant position in New York. The…
S.B. and Department of Veterans Affairs, Northport Veterans Hospital, Northport, NY
S.B. (ECAB 11-514 and 11-653): Wage capacity ruling upheld, benefits termination reversed
S.B., a former respiratory therapist at a veterans hospital, received compensation for accepted back and neck injuries. She challenged a wage-earning capacity ruling based on a telephone solicitor position and a later termination for refusing a medical support assistant position in New York. The…
J.B. and Department of the Army, Army National Guard, Lincoln, NE
J.B. (ECAB 11-1004): Back injury claim denial upheld
J.B., an Army National Guard trades worker, reported twisting his back while moving heavy metal sheets at work. OWCP accepted that the incident occurred but denied his injury claim. The Board found that his physicians described pain or possible joint involvement without a firm diagnosis and…
J.M. and U.S. Postal Service, Post Office, Philadelphia, PA
J.M. (ECAB 11-912): Wage-loss claim after authorized injections sent back
J.M., a postal carrier with an accepted lumbar injury, claimed lost wages after authorized epidural injections for his back condition. OWCP denied the claim as an unproven recurrence of disability. The Board found that wage loss while obtaining authorized treatment is compensable, so J.M. was…
C.M. and Department of Defense, Education Activity, Savannah, GA
C.M. (ECAB 11-892): Wage-earning capacity ruling remains in place
C.M., a maintenance mechanic for a Defense Department education activity, returned to work after an accepted cervical injury and later lost his position in a reduction in force. OWCP had used his actual earnings in the returned position to determine his wage-earning capacity. He argued that the…
A.D. and U.S. Postal Service, Post Office, Vineland, NJ
A.D. (ECAB 11-866): Schedule award pay rate sent back for review
A.D., a part-time flexible postal carrier, received a schedule award for an accepted back injury that caused left-leg impairment. He challenged the weekly pay rate used to calculate the award. The Board found conflicting pay figures in the record and an inadequate explanation of why OWCP used its…
E.S. and U.S. Postal Service, Largo Post Office, Largo, FL
E.S. (ECAB 11-864): Additional arm impairment award denied
E.S., a former postal carrier, sought a larger schedule award for impairment of both arms after accepted shoulder conditions. The Board reviewed the shoulder motion measurements under the sixth edition of the A.M.A. Guides and found no support for more than 27 percent impairment from the shoulder…
J.R. and Department of Agriculture, Forest Service, Camp Big Horn, Plains, MT
J.R. (ECAB 11-845): End of wage-loss compensation upheld
J.R., a Forest Service social services assistant, received compensation after an accepted right knee injury and surgery. Her treating surgeon later released her to full duty without restrictions. The Board found his report sufficient to show that the accepted injury no longer kept her from…
C.J. and U.S. Postal Service, Post Office, Nashville, TN
C.J. (ECAB 11-746): Mail carrier's thumb condition claim denied
C.J., a postal carrier, reported pain in both thumbs while sorting and delivering mail. His physician diagnosed carpometacarpal synovitis and later said that thumb use at work more likely than not contributed to it. The Board found that the physician had earlier called the cause unclear and did not…
F.H. and Department of Agriculture, Food Safety and Inspection Service, Minneapolis, MN
F.H. (ECAB 11-738): Parking-lot injury claim denied
F.H., a federal food inspector, was in a vehicle collision while waiting for a space in a designated work parking area. The collision occurred about 80 minutes before his scheduled shift. The Board found that he was not required to arrive that early, was not then preparing for work, and had chosen…
J.S. and Department of Veterans Affairs, Boston Healthcare System, Brockton, MA
J.S. (ECAB 11-408): Shoulder injury claim denial upheld
J.S., a Veterans Affairs investigator, said his left shoulder buckled while he leaned on that arm and removed camera equipment during a surveillance assignment. The Board accepted that the work incident occurred. It found that his surgeon diagnosed shoulder conditions but did not explain how that…
D.O. and U.S. Postal Service, Main Post Office, Union, NJ
D.O. (ECAB 11-383): Eight-percent awards for each arm upheld
D.O., a postal distribution clerk, received awards for accepted bilateral carpal tunnel syndrome and a left ulnar nerve condition. She sought larger awards and argued that OWCP should have used the fifth edition of the A.M.A. Guides because she filed her claim before the sixth edition took effect…
Secretary of Labor on behalf of Thurman Wayne Pruitt v. Grand Eagle Mining, Inc.
Reinstatement and discrimination cases dismissed
The Secretary asked to withdraw temporary-reinstatement and discrimination complaints involving miner Thurman Wayne Pruitt and Grand Eagle Mining. Pruitt agreed to the withdrawal based on a mutually agreeable settlement. Judge Gary Melick permitted the withdrawal under 29 C.F.R. § 2700.11 and…
River Sand & Gravel, LLC
Fall-protection violation upheld and penalty reduced to $3,500
An MSHA inspector saw a miner inspecting an elevated inclined shaker without fall protection at River Sand & Gravel's small Kentucky operation. Judge Thomas P. McCarthy found that the unguarded work exposed miners to falls of five to eleven feet onto catwalks and potentially more than thirty feet…
P.H. and U.S. Postal Service, Post Office, New York, NY
P.H. (ECAB 11-1123): Late oral-hearing request denied
P.H., a postal mail handler, requested an oral hearing after OWCP denied her occupational disease claim. She made the request more than 30 days after OWCP’s June 3, 2010 decision. The Board held that the request was too late to create a right to a hearing and that OWCP exercised its discretion when…
C.S. and Department of the Treasury, Internal Revenue Service, Kansas City, MO
C.S. (ECAB 11-1056): Continuation of pay denied after late filing
C.S., an IRS customer service representative, injured his knee at work on July 15, 2010, and OWCP accepted the injury. He filed his traumatic injury claim on August 17, one day after the extended 30-day deadline for continuation of pay. The Board distinguished the longer period for filing a…
J.H. and Department of Homeland Security, Customs and Border Protection, Pharr, TX
J.H. (ECAB 11-933): Wrist injury claim denied for lack of a diagnosis
J.H., a Customs and Border Protection canine officer, reported wrist symptoms when his dog unexpectedly jerked its leash. OWCP accepted that the incident happened. The Board found that the medical reports described pain and possible swelling but did not diagnose a specific injury or explain how the…
E.M. and U.S. Postal Service, Post Office, Somerdale, NJ
E.M. (ECAB 11-885): Eight-percent left arm award upheld
E.M., a postal carrier, sought a larger schedule award for a left-thumb injury sustained in a dog bite. He argued that earlier assessments under the fifth edition of the A.M.A. Guides created a medical conflict and that OWCP should have used that edition. The Board held that the sixth edition…
D.S. and U.S. Postal Service, Post Office, Oakland, CA
D.S. (ECAB 11-831): Modified mail handler wage rating upheld
D.S., a postal mail handler with accepted wrist and nerve conditions, returned to a full-time modified position. OWCP used her actual earnings in that position to set her wage-earning capacity. She later sought a change, arguing that the job was makeshift and that her condition had worsened. 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.