Positional Risk Doctrine Virginia

In Plumb Rite Plumbing Serv. v. Barbour, 8 Va. App. 482, 382 S.E.2d 305 (1989), the Court held that a claimant is required "to show that the conditions of the workplace or that some significant work related exertion caused the injury." Id. at 484, 382 S.E.2d at 306. "The mere happening of an accident at the workplace, not caused by any work related risk or significant work related exertion, is not compensable." Id. Virginia has rejected the "positional risk" doctrine which compensates employees who are injured on the job regardless of whether the injury was caused by a risk or condition of the workplace. See County of Chesterfield v. Johnson, 237 Va. 180, 183-84, 376 S.E.2d 73, 75 (1989) at 75-76.