What is the impact of a future care costs award on a plaintiff's ability to control her mental health?

The extent, if any, to which a future care costs award should be adjusted for contingencies depends on the specific care needs of the plaintiff. In some cases negative contingencies are offset by positive contingencies and, therefore, a contingency adjustment is not required. In other cases, however, the award is reduced based on the prospect of improvement in the plaintiff’s condition or increased based on the prospect that additional care will be required. Each case falls to be determined on its particular facts: Ferguson v. Watt, 2018 BCSC 1587 at paras. 160-163. Position of parties and decision