From Houston v. Federal Medical Center Carswell, 2010 WL 363479 (N.D. Tex. Feb. 2): “She [plaintiff] seeks compensatory monetary damages and seeks a ‘passion release.'”
Fortunately, the court goes on to explain, in a footnote: “The reference to a ‘passion release’ is likely to the Bureau of Prisons’s ‘compassionate release’ program.” Glad that got cleared up.