Can a jury award emotional distress damages for a plaintiff who lost her disability benefits because she was unable to work because of the lack of expert testimony?

Numerous cases approve the award of emotional distress damages based on the testimony of nonexpert witnesses. In Little v. Stuyvesant Life Ins. Co. (1977) 67 Cal.App.3d 451, 465, 136 Cal.Rptr. 653, the appellate court affirmed the jury's award of emotional distress damages because there was sufficient evidence to support it. The opinion does not indicate any expert testimony was offered to establish the plaintiff's emotional distress. Rather, the opinion quotes the plaintiff's own testimony that the loss of her disability benefits led to her need to borrow money and the sale of her home, which caused her "to feel that she was 'just nothing any more, useless.' She was deeply depressed. She testified: 'I justI didn't feel likeI didn't want to sell my house; I didn't want to leave andI had three children down there [in San Bernardino], grandchildren; nice neighbors. [] The house I had was very efficient; it waswas something I had always dreamed of, maybe, a little Spanish house. All my furniture was Spanish. [] It was something I fell

[25 Cal.App.5th 1097]