What is the threshold for a plaintiff to be denied employment because of a motor vehicle accident?

As noted, I have found the Perren threshold to have been readily met. The plaintiff is a physically changed man. He cannot do many of the physical tasks he could prior to the Accident. He has ongoing pain of one form or another (neck, shoulders, back, headaches). Further, I adopt Justice Frankel’s observation in writing for our Court of Appeal in Morlan v. Barrett, 2012 BCCA 66 stated at para. 41: In my view, it was open to the trial judge to find - essentially as a matter of common sense - that constant and continuous pain takes its toll and that, over time, such pain will have a detrimental effect on a person’s ability to work, regardless of what accommodations an employer is prepared to make.