Returned or returning Peace Corps volunteers?

Larry Cuban writing about

school reform

used a past-participle noun modifier, ‘returned’ rather than ‘returning.’

[A] belief in the power of schools .. took me to Washington .. to train returned Peace Corps volunteers ..

In the previous article

he used ‘returning’

The Cardozo Project in Urban Teaching, as it was then called, prepared returning Peace Corps Volunteers to teach in urban schools.

In ‘interesting/interested’, the difference distinguishes between the source and target of the modifier, expanding as active/passive phrases.

But in other cases, like ‘fallen soldiers’ and ‘misbehaved students’, it doesn’t.

Did he not use ‘prepared returned’ in the previous article because it was 2 past participles in succession?

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