Several factors are weighed when quantifying the value of the loss of enjoyment of life.

• Age of the plaintiff
• Where the plaintiff lives
• Educational background and employment history
• Extent of the injuries
• Short and long-term effects of the injury
• Activities that the plaintiff can no longer do

Unless rehabilitation is commenced immediately, and even when it is, an injury victim is prone to extreme depression, frustration, and at times, a lack of a will to live. All of these emotional tolls are taken into consideration when calculating the loses.

While expert testimony is generally not admissible regarding the computation of a dollar amount for a general damage award, expert testimony should be used to validate depression and the emotional well being (or lack thereof), of the victim. Psychiatrists, psychologists, and neuropsychologists should be utilized to discuss the diagnosis of depression, the impact of medication and the prognosis of the plaintiff’s emotional condition.

In addition to experts, lay witnesses, including family members, close friends, relatives, etc. should be used to establish the plaintiff’s damages.

Physical disabilities in a spinal cord injury case can be disheartening. The true invisible injury, however, the general damages, are no less disheartening to endure.

Extensive time must be spent by counsel in order the breadth of the general damages is understood and communicated to the jury.