What is an award for homemaking in a motor vehicle accident?

An award ordered for homemaking is for the value of the work that would have been done by the plaintiff but which she is incapable of performing because of the injuries at issue. The plaintiff has lost an asset: her ability to perform household tasks that would have been of value to herself as well as others in the family unit but for the accident: Westbroek v. Brizuela, 2014 BCCA 48 at para. 74.

In Dykeman v. Porohowski, 2010 BCCA 36 at para. 28, our Court of Appeal summarized the governing principles with respect to awarding damages for the loss or impairment of housekeeping capacity. Madam Justice Newbury confirmed that damages for the loss of housekeeping capacity may be awarded even though the plaintiff has not incurred any expense because housekeeping services were gratuitously replaced by a family member. Moreover, since the award recognizes the impairment of housekeeping capacity, whether a plaintiff is likely to hire such assistance in the future does not inform the analysis. The amount of compensation awarded must be commensurate with the plaintiff’s loss: Dykeman at para. 29.