In Baltimore and Ohio Railroad Co. v. Bowen, 60 Md. App. 299, 301, 482 A.2d 921 (1984) hereinafter "Bowen", the plaintiff applied for a railroad personnel position, but an examination by the defendant's, a railroad company, physician indicated that a bullet was lodged in the plaintiff's lumbar vertebra. As a result, the defendant did not hire him. Id. The plaintiff filed a complaint with the State Commission on Human Relations, contending that the defendant discriminated against him based on his physical disability. Id. at 302. Upon a finding of unlawful employment discrimination, the defendant appealed to the circuit court, which affirmed the Commission's ruling. Id. at 304. On appeal to our Court regarding the burden of proof, the Court stated: . . . Once the plaintiff established a prima facie case of handicap discrimination -- that he was physically able to perform the duties of a carman's helper -- the burden of persuasion properly shifted to the defendant to establish to a "reasonable probability" its defense that the plaintiff's physical handicap would create a future hazard to his health or safety. Id. at 309. The Court examined the defendant's evidence, including testimony from a railroad employee, who stated that workers were required to lift heavy equipment and often bend in uncomfortable positions, as well as the physician's testimony, who asserted that there was a possible danger of additional injuries. Id. at 303-04. The Court stated that the defendant's evidence was insufficient, as it only demonstrated a risk of a future hazard, and there was testimony that the plaintiff was physically competent to perform the duties. Id. at 313. Accordingly, the Court affirmed the circuit court's ruling. Id.