A New Leaf, Inc. v. Webb
In A New Leaf, Inc. v. Webb, 257 Va. 190, 511 S.E.2d 102 (1999), the Supreme Court addressed the distinction between injury and disease.
Webb, a flower shop employee, suffered allergic contact dermatitis resulting from physical contact with chemicals in flowers.
Her condition was described as a "reaction of the body's immune system to the substance to which that person is sensitive." Id. at 197, 511 S.E.2d at 105.
Distinguishing between the body's response to irritating stimuli and physical impairment based on cumulative trauma resulting from repetitive motion, the Court held that Webb's condition was a disease. Webb. 257 Va. at 197-98, 511 S.E.2d at 105.