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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General Services Administration, Las Vegas Fleet Management Center, Sparks Field Office and American Federation of Government Employees, Council 236
GSA Sparks Field Office (FLRA SF-RO-30080): Single-employee unit petition dismissed
AFGE Council 236 sought an election to add the sole equipment specialist at GSA's Sparks Field Office to an existing consolidated bargaining unit. A regional director dismissed the petition because the proposed one-employee unit was not appropriate. The Authority granted review to decide that legal…
Jim Walter Resources, Incorporated
Walkaround and discrimination violations found
Jim Walter Resources operated an underground coal mine where miner representative Carroll Johnson accompanied an MSHA inspection focused on respirable dust controls. Judge Avram Weisberger found that Johnson was engaged in protected activity when he helped the inspection and that the company…
Peabody Coal Company
Electrical citations affirmed as significant and substantial
MSHA cited Peabody Coal Company after finding that a cathead's external grounding wires were disconnected and that another cathead was not plainly marked. Judge Arthur J. Amchan found both violations significant and substantial under the Mathies test. He affirmed both citations and assessed a $189…
James Barry v. Sea-Land Services, Incorporated
Barry v. Sea-Land Services (BRB 92-1238): late-payment penalty upheld with interest
Sea-Land Services settled James Barry's Longshore Act injury claim but issued the $4,090.51 payment check more than ten days after the settlement order was filed. An administrative law judge imposed the Act's 20 percent late-payment penalty, and the employer argued that federal court time-counting…
U.S. Office of Personnel Management, Atlanta Regional Office of Federal Investigations and American Federation of Government Employees, AFL-CIO
OPM Atlanta investigations office (FLRA AT-RO-30011): Review of bargaining unit dismissal denied
AFGE sought an election for a bargaining unit covering employees of OPM's Investigations Division in its Atlanta Region. A regional director dismissed the petition because the proposed unit lacked a distinct community of interest and would not promote effective dealings with the agency. The…
U.S. Customs Service, Region IV, Miami, Florida and National Treasury Employees Union
Customs Service Miami and NTEU (FLRA 4-CA-10904): Overtime report disclosure dispute remanded
NTEU requested two management reports while bargaining over overtime assignments and shifts in the Customs Service's Miami District. An administrative law judge found that the agency had to provide one report but not the other. The Authority held that a Freedom of Information Act exemption did not…
U.S. Department of the Navy, Headquarters, Naval District Washington and Fraternal Order of Police, U.S. Navy Yard Labor Committee
Naval District Washington (FLRA 0-AR-2512): Fee denial set aside after suspension reversal
A Navy employee was suspended for 14 days after being charged with absence without leave. An arbitrator found that the employee had supplied sufficient medical documentation and ordered the Navy to remove the suspension and restore lost pay and benefits. He denied the union's request for attorney…
U.S. Department of Justice, Immigration and Naturalization Service and National Immigration and Naturalization Service Council, Local 46, American Federation of Government Employees
INS Detroit District (FLRA 0-AR-2471): Snowstorm leave requests must be reviewed
A snowstorm kept some INS Detroit District employees from reporting to work on January 14, 1992. The agency charged those employees annual leave or leave without pay because the office had opened that morning. An arbitrator found that the agency's own rule allowed administrative leave even when an…
American Federation of Government Employees, AFL-CIO, Local 2782 and U.S. Department of Commerce, Bureau of the Census
AFGE Local 2782 and Census Bureau (FLRA 0-NG-2162): Reserved union parking proposal is negotiable
AFGE Local 2782 proposed a reserved parking space for union use under a Census Bureau building. The agency argued that federal parking rules required it to give the space to higher priority users, including carpools. The Authority found that those rules set priorities for assigning reserved spaces…
U.S. Department of Transportation and Federal Aviation Administration and Professional Airways Systems Specialists, MEBA, AFL-CIO
FAA drug testing remedy (FLRA 3-CA-70647-1-2): existing order reaffirmed
The Authority had found that the FAA violated its bargaining duty when it implemented a drug testing program for employees represented by the union. A federal appeals court returned the case for a fuller explanation of why the Authority denied a return to the conditions before the program. On…
National Park Service, National Capital Region, United States Park Police and Police Association of the District of Columbia
U.S. Park Police and Police Association of D.C. (FLRA 3-CA-60168): Disclosure violation upheld in part
The Police Association requested supervisors' recommendations about discipline and sick leave decisions for Park Police employees whose grievances it handled. After a court remand, the Authority held that the union had shown a particularized need for the disciplinary recommendations because the…
National Association of Government Employees, Local R14-52 and U.S. Department of the Army, Red River Depot, Texarkana, Texas
NAGE Local R14-52 and Red River Depot (FLRA 0-NG-1807): Gainsharing proposal held negotiable on remand
NAGE Local R14-52 proposed a gainsharing program for civilian employees at the Army's Red River Depot. After a federal appeals court sent the case back, the Authority clarified when a bargaining proposal interferes with management's right to determine its budget. It interpreted the union's proposal…
United States Information Agency and American Federation of Government Employees, Local 1812
USIA and AFGE Local 1812 (FLRA 0-AR-2557): Late arbitration exceptions dismissed
AFGE Local 1812 filed exceptions to an arbitration award in a dispute with the United States Information Agency. The award was served by mail on October 26, 1993, and the Authority calculated November 29 as the last day to file exceptions after the mailing allowance. The union's exceptions were…
Braithwaite v. Tri-Star Mining
Discrimination complaint dismissed
Vincent Braithwaite worked as a heavy equipment operator at Tri-Star Mining and refused to operate a large dump truck because he felt uncomfortable operating it. An Administrative Law Judge had found that the refusal was protected and awarded damages after finding that Tri-Star unlawfully…
U.S. Department of Defense, National Guard Bureau, North Carolina Air National Guard, Charlotte, North Carolina; John A. Teague, Jr.; and Association of Civilian Technicians, Tarheel Chapter
North Carolina Air National Guard (FLRA AT-DR-20035): Election objections dismissed
The Association of Civilian Technicians challenged the results of a decertification election among North Carolina Air National Guard civilian technicians. It argued that the activity restricted union access and bulletin board use during the campaign and should have bargained over campaign…
Benevento Sand and Gravel
Citations affirmed with modifications
Benevento Sand and Gravel, a small quarry and mill operator, faced eight citations and orders involving truck alarms, seat belts, a loader passenger, a conveyor guard, and other equipment conditions. Judge Paul Merlin affirmed the fact of each violation and most significant and substantial and…
Martinka Coal Company
Withdrawal orders affirmed
MSHA cited Martinka Coal Company for coal and coal-dust accumulations under a belt line and for frozen or missing belt rollers that left the belt rubbing against its supporting structure. After Martinka received five days to abate the conditions, an inspector found that some violations remained and…
Saginaw Mining Company
Settlement disapproved pending more information
Saginaw Mining Company faced three citations after an October 23, 1991 roof-fall accident at the Saginaw Mine that caused fatal injuries to a mine foreman and serious injuries to a construction foreman. The Secretary proposed reducing the total civil penalties from $21,000 to $15,000, but the…
American Federation of Government Employees, Local 1923 and U.S. Department of Health and Human Services, Social Security Administration, Philadelphia, Pennsylvania
AFGE Local 1923 and SSA Philadelphia (FLRA 0-AR-2452): Performance rating award stands
An SSA employee grieved several ratings in a performance appraisal. The arbitrator found that the employee had been rated on use of a processing system without being told that it was part of the performance standard. He raised one task rating from level 3 to level 4 and ordered SSA to recalculate…
Consolidation Coal Company, Incorporated
Electrical violations modified
Consolidation Coal was cited after an underground mine inspector found missing bolts on a high-voltage splitter box and later saw the box returned to service before it was repaired. Judge David F. Barbour affirmed the underlying violation for the unsafe splitter box and found it significant and…
TTX Company, Acorn Division
Lead-exposure items vacated, notice duties affirmed
TTX repaired railroad cars in Jacksonville, Florida, using cutting, welding, and grinding processes that could disturb lead-based paint on older cars. The judge vacated a permissible-exposure-limit item because OSHA placed its sampling cassette outside the employee's welding helmet even though the…
Bermudez & Longo, S.E.
Mixed ruling on grinder and electrical violations
OSHA inspected Bermudez & Longo's construction site in Guaynabo, Puerto Rico. The judge affirmed two serious grinder violations because an accessible bench grinder used by employees lacked a work rest and a safety guard, assessing $375 for each item. He vacated a third grinder item because the…
Jamieson Company
Guarding citations mixed, total penalty $510
Jamieson Company operated a medium-sized, one-plant sand and gravel operation with 50 employees. Judge Michael A. Lasher addressed seven MSHA citations under two machine-guarding standards, vacating one citation and litigating the six remaining citations. He affirmed violations involving unguarded…
Materials Delivery
Seven citations affirmed
Materials Delivery operated a sand and gravel pit that had not notified MSHA that operations had begun. Judge Arthur J. Amchan also found violations involving inoperative loader horns and a reverse alarm, unsecured compressed-gas cylinders, missing toilet facilities, and a raised loader bucket. He…
Secretary of Labor o/b/o Shepherd v. Sovereign Mining Company
Temporary reinstatement issues remanded
An Administrative Law Judge ordered Danny Shepherd's temporary reinstatement after finding that his discrimination complaint was not frivolous. Shepherd was laid off the next day, and the Secretary asked the Commission to compel compliance with the reinstatement order or send the matter back to the…
Super Sky Products, Inc.
Atrium fall-protection violations affirmed
A Super Sky employee was water-testing a sloped glass atrium in Cleveland while working from a narrow gutter high above the patio below. A Labor Department attorney and OSHA supervisor watched through binoculars and saw that the employee was not tied to the safety line, although Super Sky disputed…
United States Steel Mining Company, Inc.
Safeguard violation affirmed, S&S issue remanded
MSHA cited United States Steel Mining Company after trolley poles repeatedly disengaged from the trolley wire at the Gary No. 50 Mine in West Virginia. The Commission held that the safeguard notice gave the operator fair notice that trolley wire had to be kept within a proper distance of the track…
Slade Vanover v. Shamrock Coal Company
Discrimination complaint dismissed
Slade Vanover worked as a longwall technician for Shamrock Coal Company and complained about dust, underground detonations, and the transport of explosives on a mantrip. He claimed that the company ignored those concerns and constructively discharged him when he left in July 1992. Judge George A…
Raymond Byrd and Vincent T. Nolfe v. Alabama Dry Dock and Shipbuilding Corporation
Byrd and Nolfe v. Alabama Dry Dock (BRB 92-930): hearing-loss settlements set aside
Byrd and Nolfe each agreed with Alabama Dry Dock on hearing-loss benefits and proposed that the federal Special Fund pay part of the awards. An administrative law judge approved the agreements, but the Director of the Office of Workers' Compensation Programs challenged the Fund's assigned…
Safeway Store No. 914
Commission affirms hazard-communication violations without penalty
OSHA cited a Safeway grocery store in Loveland, Colorado, for hazard-communication deficiencies involving a windshield washer used to clean checkout scanners and a sanitizer used in the meat department. The Commission held that the citations were timely because OSHA issued them within six months…
Kaspar Electroplating Corp.
Commission affirms three machine-guarding violations and vacates drill-press items
OSHA cited Kaspar Electroplating after inspecting its Shiner, Texas facility. On review, the Commission rejected Kaspar's argument that the citation was untimely, finding that OSHA issued it within six months of discovering the uncorrected conditions. It also held that a compliance officer may…
Unarco Commercial Products
Commission holds plating-tank footholds were not platforms
Unarco manufactured shopping carts on an automated electroplating line in Wagoner, Oklahoma. Employees sometimes stood on narrow PVC pipes, copper anode rails, or carry arms to retrieve parts that had fallen into chemical tanks, and one employee had suffered serious burns after falling into a tank…
J.A. Jones Construction Co.
Commission affirms item-specific fall-protection penalties
This case returned to the Commission after an earlier decision affirmed numerous serious, rather than willful, fall-protection violations at J.A. Jones Construction's Chicago high-rise project and remanded for item-specific penalties. On remand, the ALJ evaluated the fall distance, degree of…
U.S. Department of Defense, Defense Finance and Accounting Service, Indianapolis Center and American Federation of Government Employees, Local 1411
DFAS Indianapolis and AFGE Local 1411 (FLRA 0-AR-2475): Security badge grievance denial stands
DFAS directed security guards at its Indianapolis facility to wear Department of Defense police badges and shoulder insignia instead of security guard insignia. AFGE Local 1411 grieved the change, but an arbitrator held the grievance outside arbitration and denied it. The Authority denied the…
American Federation of Government Employees, Local 1923 and Department of Health and Human Services, Health Care Financing Administration
AFGE Local 1923 and HHS Health Care Financing Administration (FLRA 0-AR-2449): Late attorney fee request remains denied
Two Health Care Financing Administration employees attended a union convention, and the agency charged them as absent without leave. An arbitrator removed the absence charges but left the type of replacement leave to be determined. The union later sought attorney fees, which the arbitrator denied…
Guess, employed by Pyro Mining Company
Individual penalty proceedings dismissed
The Secretary sought individual civil penalties against Donald Guess and Paul Shirel for allegedly authorizing, ordering, or carrying out Mine Act violations at the William Station Mine. The Commission held that section 110(c) imposes individual liability on agents of corporate operators, while…
Equal Employment Opportunity Commission, San Diego Area and American Federation of Government Employees, Local 3230
EEOC San Diego and AFGE Local 3230 (FLRA 98-CA-10517): coercive statements violate labor statute
The San Diego area director of the Equal Employment Opportunity Commission told employees that he would remember employees who challenged him through complaints to superiors or the union. An administrative law judge found that the statements interfered with employees' protected labor rights. The…
U.S. Department of Transportation, Federal Aviation Administration, Burlington, Massachusetts and National Air Traffic Controllers Association
FAA Burlington and NATCA (FLRA 0-AR-2464): training remedy sent back for clarification
An FAA air traffic controller was returned to a lower grade after an unsuccessful certification evaluation. An arbitrator found that the controller's training was unfair and ordered reinstatement into training retroactive to the day of the demotion. The Authority rejected the FAA's arguments that…
Central Florida Underground, Inc.
Crane and rigging violations affirmed after fatal power-line contact
Central Florida Underground was an underground pipe contractor whose crew used a crane to move a trench box near energized overhead electrical lines. During the work, the crane boom contacted the lines and an employee touching the crane was electrocuted. The judge found that Central failed to train…
Container Corporation of America
Three disputed paper-mill safety items vacated
Container Corporation of America operated a paper mill in Fernandina Beach, Florida. The parties settled most citation issues before the hearing, leaving three items concerning wet and oily floors, protective clothing for welders, and insulation or guarding of steam pipes. The judge vacated the…
Air Products and Chemicals, Inc.
Mine jurisdiction and entry citation affirmed
Air Products and Chemicals processed coal refuse and run-of-mine coal at its Cambria Co-Generation Facility to produce electricity and steam. The Commission held that the coal-handling facilities were subject to Mine Act jurisdiction because the company broke, crushed, sized, and stored coal…
J & S Collieries, Inc.
Discrimination settlement approved
Herbert Collins brought a Mine Act discrimination complaint against J & S Collieries after his employment ended. Judge Paul Merlin approved a settlement under which the company paid Collins $5,000, expunged related personnel records, and agreed to provide only neutral employment information to…
Gouverneur Talc Company
Discrimination complaint dismissed
Thomas P. Gates filed a Mine Act discrimination complaint after Gouverneur Talc Company permanently discharged him following an altercation with a coworker. He argued that the company's later arbitration process was tainted by his discrimination complaint and that his discharge was related to…
General Chemical Company
USWA (Ronald Shane Bird) v. General Chemical Company (FMSHRC WEST 92-596-DM): Mine Act discrimination complaint dismissed
Ronald Shane Bird, a bore miner operator at General Chemical's underground trona mine, alleged that reprimands and crew reassignments followed his safety complaint about a high cut in the mine roof. Judge Michael A. Lasher, Jr. found that Bird's initial safety complaint and request for a safety…
U.S. Department of Defense, Dependents Schools and Overseas Education Association and Overseas Federation of Teachers and Panama Canal Federation of Teachers
DOD Dependents Schools and OEA (FLRA WA-CU-20896): Panama and Mediterranean units remain separate
The Overseas Education Association sought to add employees at Defense Department schools in Panama and the Mediterranean to its broader bargaining unit. It argued that centralized personnel functions had made the existing regional units inappropriate. A regional director rejected the proposed…
Manalapan Mining Company, Inc.
Settlement approved for $12,100
Manalapan Mining Company faced civil penalty proceedings across four dockets involving Mine Nos. 1, 6, and 7. Judge Roy J. Maurer approved a settlement that reduced the proposed penalties from $14,612 to $12,100. The company was ordered to pay the settlement amount within 30 days, and the cases…
MATTER OF G-
Golden Venture arrival did not establish entry
The applicant, a Chinese citizen who arrived on the Golden Venture, argued that reaching shore after the vessel grounded meant he had entered the United States and therefore could not be placed in exclusion proceedings. The Board held that an entry requires physical presence, inspection or…
National Federation of Federal Employees, Local 1998 and U.S. Department of State, Bureau of Consular Affairs, Passport Services
NFFE Local 1998 and State Department Passport Services (FLRA 0-AR-2498): exceptions dismissed as moot
The State Department challenged an arbitration award involving its Passport Services office. The union then withdrew the grievance that had produced the award and asked the Authority to dismiss the case. The agency argued that dismissal would leave the union free to file new grievances on the same…
U.S. Department of Veterans Affairs, Medical Center, Danville Veterans Hospital, Danville, Illinois and American Federation of Government Employees, Local 1963
VA Danville hospital and AFGE Local 1963 (FLRA 0-AR-2472): smoking shelter remedy stands
The VA hospital in Danville ended use of indoor smoking areas as part of a smoke-free workplace policy. An arbitrator found that 11 outdoor shelters did not adequately protect users from local weather, as a Federal Service Impasses Panel order required. She ordered the hospital to correct the…
U.S. Department of Transportation, Federal Aviation Administration, Washington, D.C. and National Air Traffic Controllers Association
FAA and NATCA (FLRA 0-AR-2462): performance appraisal system must meet objective standards
The FAA used five rating levels for air traffic control specialists but had a written performance standard only at the fully successful level. NATCA challenged the system, and an arbitrator found that supervisors lacked guidance for ratings above and below that level. The arbitrator ordered the FAA…
Marine Corps Base, Camp Lejeune, North Carolina and American Federation of Government Employees, Local 2065
Camp Lejeune and AFGE Local 2065 (FLRA AT-CA-30133): smoking policy complaint dismissed
Employees at a Camp Lejeune clothing warehouse had been allowed to smoke inside. The Marine Corps moved the designated smoking area to a covered outdoor loading dock without giving the union notice or a chance to bargain. A complaint alleged that the move was an unfair labor practice. The Authority…
American Federation of Government Employees, SSA General Committee and Department of Health and Human Services, Social Security Administration
AFGE SSA General Committee and SSA (FLRA 0-AR-2450): attorney fee denial upheld
The union won part of an arbitration grievance over official time for representatives attending its national convention. After the Authority denied the agency's exceptions to that award, the union sought fees for its attorney's work opposing those exceptions. The arbitrator found the request timely…
U.S. Department of Health and Human Services, Social Security Administration and American Federation of Government Employees, Local 1923
SSA and AFGE Local 1923 (FLRA 0-AR-2430): attorney fee award upheld
A Social Security Administration employee won backpay for a performance award smaller than those paid to similarly rated employees. After the Authority rejected the agency's challenge, an arbitrator awarded the union's lawyer $2,468.50 for defending the award and $760 for preparing the fee request…
Secretary of Labor o/b/o Peters v. Thunder Basin Coal Company
Secretary of Labor on behalf of Loy Peters, Donald Gregory, and Darryl Anderson v. Thunder Basin Coal Company (FMSHRC WEST 93-652-D): Temporary reinstatement affirmed
Three technicians-welders at Thunder Basin Coal's Black Thunder mine were laid off during a workforce reduction and alleged that the layoffs were illegal retaliation for exercising rights protected by the Mine Act. After an evidentiary hearing, the ALJ found their discrimination complaints were not…
U.S. Department of Health and Human Services, Social Security Administration and American Federation of Government Employees, Local 1923
SSA and AFGE Local 1923 (FLRA 0-AR-2454): employee rating returned to arbitrator
An SSA employee challenged her performance ratings on three critical job tasks. After her supervisor twice used a flawed appraisal method, an arbitrator directed the agency to mark those tasks as not applicable and calculate her overall rating from two other tasks. The Authority held that this…
American Federation of State, County and Municipal Employees, Local 2477 and Library of Congress
AFSCME Local 2477 and Library of Congress (FLRA 0-AR-2483): promotion grievance denial stands
A Library of Congress cataloger was not chosen for a promotion under an announcement used to fill one GS-9 and one GS-11 position. He challenged the selection process and alleged retaliation for union activity and advocacy for veterans' rights. An arbitrator denied the grievance, finding that the…
Veterans Administration, Long Beach, California and American Federation of Government Employees, Local 3943
VA Long Beach and AFGE Local 3943 (FLRA SA-CA-20739): information complaint dismissed
AFGE Local 3943 sought nurses' proficiency-rating dates and promotion information while pursuing a grievance about delayed ratings at the VA's Long Beach facility. The VA declined to provide the information and said the grievance was outside the negotiated grievance procedure because it concerned…
Bucket Coal Company
Dust-sampling citation vacated
MSHA cited Bucket Coal Company for failing to collect and submit five respirable-dust samples during the March and April 1992 bimonthly period. The company said its mine had been flooded and was not producing coal during the relevant period. Judge Avram Weisberger credited the company's witness and…
Cedar Lake Sand & Gravel Company, Inc.
Default order vacated and case remanded
Cedar Lake Sand & Gravel failed to answer a civil-penalty proposal and a show-cause order, so an ALJ entered a default order assessing the proposed $100 penalty. Cedar Lake later said it had timely responded to the show-cause order and asked for relief from the default. The Commission treated the…
U.S. Department of Health and Human Services, Food and Drug Administration and American Federation of Government Employees, Council 242
FDA regions and AFGE Council 242 (FLRA BY-CU-20017, BY-CU-20033): Newark employees remain in the unit
After the FDA reorganized its regions, it asked to remove Newark District Office employees from a consolidated bargaining unit represented by AFGE Council 242. It also challenged the inclusion of secretaries to first-level supervisors. The regional director found that Newark employees still shared…
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.