Richard E. Brown, Inc. v. Caporaletti

In Richard E. Brown, Inc. v. Caporaletti, 12 Va. App. 242, 402 S.E.2d 709 (1991), the claimant sustained an acute lumbosacral strain while "straightening up after working in a bent over position . . . ." Id. at 244, 402 S.E.2d at 710. The Court held that the claimant's need to work in the bent over position and to extract himself from that position was a "'hazard to which the claimant would not have been equally exposed apart from the conditions of the employment.'" Id. at 245, 402 S.E.2d at 711.