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I consider most e-readers to be as durable as phones and maybe most tablets. Probably more durable because ereaders are usually lighter for their size and hence should survive drops better. But I think we can probably agree that most people would have the expectation that if they dropped their device it could very well break.
As mentioned previously, it's the bending and twisting forces that you really have to look out for, and that most cases won't protect against as well. I can see this happening in a tightly packed backpack for sure.
That said, I have been daily carrying my ereaders around in backpacks and satchels for around nine years now (since the Sony PRS-505 first came out), each one for multiple years at a time with no case, and never had a crack. Scuffs and dented corners yes, but no crack.
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