Amazon Worker Wins Right to Medical Care but Loses Bid for Disability Pay in Tennessee Ruling

Court criticizes employer's handling of injury claim while finding injured warehouse worker failed to prove entitlement to continued wage replacement benefits after reaching maximum medical improvement.
By: | October 30, 2026
Amazon warehouse

A Tennessee workers’ compensation court has ruled that an injured Amazon warehouse worker is entitled to additional medical treatment but not additional temporary disability benefits, in a decision that highlights the tension between an employer’s obligation to provide authorized medical care and its ability to terminate wage replacement benefits once a worker reaches maximum medical improvement.

Nirmal Brar, an employee of Amazon.com Services LLC, injured his lower back while lifting heavy items at an Amazon facility on April 24, 2024. He subsequently treated with two physicians, ultimately coming under the care of Dr. John Burleson, who diagnosed back pain with left-sided radiculopathy and a lumbosacral strain.

Amazon’s workers’ compensation carrier, American Zurich Insurance Co., paid temporary disability benefits from June 2024 through April 14, 2025 — four days after Dr. Burleson placed Brar at maximum medical improvement and released him without restrictions at Brar’s own request.

Following that release, Brar continued to experience pain and seek care through Amazon-authorized physicians.

He saw Dr. Tarek Elalayli, who diagnosed sacroiliac joint pain and assigned work restrictions that Amazon did not accommodate. He was later directed to a panel of pain management specialists, eventually seeing Dr. Alex Schmidt, who ordered an MRI. However, Amazon failed to schedule a follow-up appointment for Schmidt to review the MRI results.

Brar argued that Amazon had systematically delayed his treatment throughout the claim, leaving him without income for 14 months and in debilitating pain.

Amazon countered that because no physician had formally rescinded Dr. Burleson’s maximum medical improvement determination, Brar was not entitled to additional temporary disability benefits. The company also argued that it was appropriately investigating the role of preexisting injuries in Brar’s condition by seeking causation opinions from subsequent treating physicians.

In its Oct. 20, 2026, opinion, Judge Kenneth M. Switzer of the Tennessee Court of Workers’ Compensation Claims focused on Amazon’s conduct in managing the claim. The court noted that Amazon’s letter to Dr. Schmidt seeking a causation opinion included a medical record of questionable relevance from a prior treating physician and was framed in a manner designed to elicit a finding of zero percent impairment rather than an objective medical assessment.

As the court observed, 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 found credible Brar’s testimony that he had informed Dr. Burleson of his prior back injury, contradicting Amazon’s claim that the authorized treating physician was unaware of that history.

On the question of temporary disability benefits, however, the court found that Brar had not met his burden of proof. Under Tennessee workers’ compensation law, an injured worker must demonstrate that a compensable injury caused the disability, establish a causal connection between the injury and the inability to work, and define the duration of the disability period.

None of the physicians who treated Brar after his maximum medical improvement date had provided a causation opinion linking his ongoing condition to the work injury or specified a period of renewed disability.

The court ordered Amazon to immediately schedule a follow-up appointment with Dr. Burleson and file proof of compliance within seven business days. Brar’s request for additional temporary disability benefits was denied, and a status hearing was scheduled for December 7, 2026.

View the full decision here. &

The R&I Editorial Team can be reached at [email protected].

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