The Virginia Court of Appeals in Richmond held that an Amazon worker failed to show he used enough exertion in his warehouse job to injure his shoulder. They upheld an earlier decision from the Virginia Workers’ Compensation Commission which denied his request for workers’ comp benefits.

William Bowers worked as a warehouse associate for Amazon.com Inc. He maintained merchandise on racks and removed plastic wrapping from boxes, positioning them so that they would be ready to forklift drivers.

On July 7, 2016 he said he was attempting to remove “balled-up plastic wrap” around a few boxes at the back of a pallet stacked shoulder height. He tried to pull the boxes closer to the edge to make them more accessible and felt a pop in his shoulder as he was tugging. He reported the incident and sought treatment. He filed a request for medical and temporary disability benefits.

In an interview with his adjuster he said he did not jerk the plastic or pull “with a huge amount of force”. His claim was denied because he used minimal force and was not in an awkward movement, so the injury did not arise from his employment. The Commission agreed, saying he failed to establish that significant work-related exertion caused the injury.

For an injury to be compensable under Virginia’s Workers’ Compensation Act, a claimant must prove their injury was caused by an accident, sustained in the course of employment and arising out of employment. Mr. Bowers failed to show a “causative danger” and did not exert enough force, so therefore he failed to prove his injury was caused by a work-related risk or significant work-related exertion, so the injury did not arise from employment.

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