Can't return to your old job? Not a serious impairment.

  In Luther v. Stoeckle, the Court of Appeals applied the Kreiner "life-altering" definition of "serious impairment" to deny the claim  of a woman who suffered exacerbation of a herniated disc when she was rear-ended at a stop light.  Although she could not return to her job because of physician-imposed lifting restrictions, and she could not pursue many of her prior recreational activities, and needed some help with housework, the Court said that under Kreiner, her injury was not "serious".