Both UPS and FedEx will deny your claim unless the bike was "properly packed." Their interpretation of "properly packed" includes 3 inches of padding between the bike and the box.
I have seen more than one frame where the damage to the box indicates that those wooden or plastic spacers have indeed protected the frame from much worse damage. I have also seen some sadly crushed forks, rear triangles and dropouts when those spacers were not used. ...Yes, I've shipped and unpacked a large number of bikes and frames.
Brent