Claims
Tennessee Court Faults Amazon's Claim Handling but Denies Worker Disability Pay
By Insurance Wire Staff, . Insurance Wire.
A Tennessee workers' compensation court has split the difference in a case pitting an injured Amazon warehouse worker against the company's insurer, ordering Amazon to provide further medical care while refusing to restore the wage-replacement payments it cut off last spring. Risk and Insurance reported the Oct. 20, 2026 ruling in detail; Business Insurance also covered the decision.
What happened
Nirmal Brar hurt his lower back lifting heavy items at an Amazon facility on April 24, 2024. American Zurich Insurance Co., Amazon's workers' compensation carrier, covered temporary disability benefits, the weekly wage-replacement payments an injured worker receives while unable to perform their job, from June 2024 through April 14, 2025. That cutoff came four days after the authorized treating physician, Dr. John Burleson, placed Brar at maximum medical improvement, the point at which a worker's condition is considered as healed as it is likely to get, and released him without restrictions at Brar's own request.
Brar continued to experience pain. A subsequent physician, Dr. Tarek Elalayli, diagnosed sacroiliac joint pain and imposed work restrictions that Amazon did not accommodate. Brar was then directed to a pain management specialist, Dr. Alex Schmidt, who ordered an MRI. Amazon never scheduled the follow-up appointment for Schmidt to review those results.
What the court found
Judge Kenneth M. Switzer of the Tennessee Court of Workers' Compensation Claims focused heavily on how Amazon managed the claim after the disability payments stopped. The court found that Amazon's letter to Dr. Schmidt, which sought a causation opinion, meaning a physician's formal judgment on whether the work injury produced the ongoing condition, attached a medical record of doubtful relevance from an earlier treating physician and was structured to elicit a zero percent impairment finding rather than an independent medical assessment.
As Risk and Insurance quoted from the opinion, Amazon appeared to be "seeking a negative causation opinion under the guise of providing 'second opinions', all while not paying temporary disability benefits." The court also credited Brar's testimony that he had told Dr. Burleson about his prior back injury, directly contradicting Amazon's claim that its authorized physician was unaware of that history.
On the disability payments, however, the court sided with Amazon. Under Tennessee workers' compensation law, a worker seeking renewed temporary disability benefits must show that the original work injury caused the ongoing disability and must establish the period during which that disability applies. No physician who treated Brar after the maximum medical improvement date had provided a formal opinion connecting his continued condition to the April 2024 injury or defined a renewed disability period. Without that medical foundation, the court found Brar had not met his legal burden.
The court ordered Amazon to immediately arrange a follow-up with Dr. Burleson and submit proof of compliance within seven business days. A status hearing is set for December 7, 2026.
Why this matters
The ruling illustrates a structural tension that workers' compensation professionals encounter regularly.
The court's criticism of how Amazon framed its causation request to Dr. Schmidt is the detail claims professionals should read carefully. Directing a physician toward a predetermined conclusion, rather than an independent assessment, is the kind of conduct that draws judicial scrutiny even when the employer ultimately prevails on the benefits question. Whether that criticism carries consequences beyond this proceeding, including any effect on how the December hearing goes, remains to be seen.
Sources
1. Amazon Worker Wins Right to Medical Care but Loses Bid for Disability Pay in Tennessee Ruling, riskandinsurance.com
2. Amazon ordered to provide treatment, criticized over handling of injury claim - Business Insurance, businessinsurance.com
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