Understanding Loss of Enjoyment of Life and Hedonic Damages

When someone suffers a serious injury due to another's negligence, the law allows them to seek compensation for their economic and non-economic damages. Economic damages deal with concrete figures that reflect the financial impact of a physical injury. This may range from immediate medical expenses to the long-term costs of medical care. On the other hand, non-economic damages delve into the realm of compensating for pain, suffering, and various forms of emotional distress that arise from an injury. One key aspect of non-economic damages is known as "loss of enjoyment of life" or hedonic damages.

What Are Hedonic Damages?

Hedonic damages compensate an injured person for the limitations placed on their ability to enjoy life as they once did. These damages are awarded when an injury prevents someone from participating in their usual hobbies, recreational activities, or simply deriving pleasure from day-to-day living. Examples include:

• Compensation for the inability to enjoy sports or outdoor activities.
• Damages for the loss of hearing or sight, which deeply changes daily experience and enjoyment.
• Compensation for no longer being able to pursue talents, arts, or cherished hobbies.

Importantly, these losses are understood in both a subjective sense (the person's own realization that they can no longer engage in past pursuits) and an objective sense (the measurable inability to engage in those activities).

Key Case: Ogden v. J.M. Steel Erecting, Inc.

The Arizona Court of Appeals in Ogden v. J.M. Steel Erecting, Inc., 201 Ariz. 32 (Ct. App. 2001) drew a clear distinction between two related – but different – categories of non-economic damages: pain and suffering and loss of enjoyment of life (hedonic damages).

The Ogden Court held that it was proper for the jury to be instructed on both types of damages, as they compensate for distinct aspects of human loss.

This distinction highlights that an injured person's losses extend beyond physical pain. Even if pain subsides, the inability to resume beloved activities, talents, or normal routines remains a separate, compensable harm.

Why This Matters

Recognizing hedonic damages ensures that courts account for the whole person when addressing the consequences of injury. Negligence doesn't just leave behind medical bills – it can permanently reshape how someone experiences life's pleasures.