14.15.2 Personal Injury Damages.

• Jurisdiction: Arizona

14.15.2 Personal Injury Damages. Personal injury damages generally include emotional distress damages.²⁰⁵ However, under Arizona law, plaintiffs may not recover emotional distress damages in professional negligence claims arising out of pecuniary loss.²⁰⁶ In a legal malpractice action, the court in Reed v. Mitchell & Timbanard, held that claims resulting “in pecuniary loss which in turn cause emotional upset, even with physical symptoms, will not support a claim for damages for emotional distress.”²⁰⁷...