This item was on the 05-2012 LoAR

14: Marek Casimir of Krakow - New Device
OSCAR finds the name registered exactly as it appears in May of 2012, via the East
Checky sable and argent, a chief enarched argent, overall an eagle gules.
Precedent states that, "Overall charges may not surmount peripheral charges such as chiefs. "The orle overlying the point violates the rule prohibiting overall charges over peripheral charges." (LoAR October 1999, p. 22). [Miles de Colwell, 12/2001, R-Lochac]" A recent return stated that, "Additionally, no evidence was presented as to whether an overall charge may overlie peripheral ordinaries. Commenters were able to find some evidence that overall charges occasionally were found overlying a single peripheral ordinary." [Pompeia Karîna, 04/2011, R-Ealdormere] The evidence cited above included the following, all from the c. 1405 Wapenboek Beyeren:
Barry azure and argent, a chief Or and overall a lion gules (http://www.kb.nl/bladerboek/wapenboek/browse/page_008v.xml) and Barry argent and azure, a chief Or and overall a lion gules (http://www.kb.nl/bladerboek/wapenboek/browse/page_030r.xml) - both examples are for the same person
Argent, a chief gules and overall a lion azure (http://www.kb.nl/bladerboek/wapenboek/browse/page_006v.xml)
Another independent example was found: image 110/111 of the Wappenbuch der Arlberg-Bruderschaft, dated 1548 (http://bilderserver.at/wappenbuecher/VirgilRaberEXAv2_52z2/), shows a ox with its horns overlying a chief.
As such, it is hoped that the precedent can be explicitly overturned.