How have courts limited damages for intangible loss in personal injury cases?

The court again recognized the need to limit recovery of monetary damages for intangible loss in Turpin v. Sortini (1982) 31 Cal.3d 220, 237, 182 Cal.Rptr. 337, 643 P.2d 954. There, in an action for "wrongful life," the court limited damages to economic loss and observed that "a monetary award of general damages ... cannot in any meaningful sense compensate the plaintiff."

[48 Cal.3d 666] iOchoa v. Superior Court, supra, 39 Cal.3d 159, 165, footnote 6, 216 Cal.Rptr. 661, 703 P.2d 1, ⁹ offers additional guidance, justifying what we acknowledge must be arbitrary lines to similarly limit the class of potential plaintiffs if emotional injury absent physical harm is to continue to be a recoverable item of damages in a negligence action. The impact of personally observing the injury-producing event in most, although concededly not all, cases distinguishes the plaintiff's resultant emotional distress from the emotion felt when one learns of the injury or death of a loved one from another, or observes pain and suffering but not the traumatic cause of the injury. Greater certainty and a more reasonable limit on the exposure to liability for negligent conduct is possible by limiting the right to recover for negligently caused emotional distress to plaintiffs who personally and contemporaneously perceive the injury-producing event and its traumatic consequences.