# Can I include other costs caused by an injury?

Canonical: https://californiapersonalinjurylaws.com/guides/out-of-pocket-costs/

Reviewed by Andrew (Andy) R. Gillin; publisher reported approval on 2026-11-04. Original review date was not supplied.

## Short answer

A claim may cover some costs you paid because of the injury. The costs must fit the legal rules. Keep proof of what you paid and why.

## Hypothetical example

A person saves receipts for trips to the doctor. They also track help needed while they heal.

## How the rule works

A receipt proves a payment, but it does not prove the full legal claim. You also need to explain why the injury made the expense necessary. Keep the reason with the receipt.

## What can change the answer

Not every cost can be claimed. The kind of case matters. You may need to show that a cost was reasonable and needed.

## A useful next step

Keep each receipt. Note the date, purpose, and link to the injury.

## Court decisions behind this answer

### Howell v. Hamilton Meats & Provisions, Inc. (2011)

52 Cal.4th 541, slip op., pp. 1–2. For the insured care at issue, a bill’s unpaid negotiated writeoff was not a loss the patient could recover.

Limit: This case addressed medical expenses. Other out-of-pocket costs still need proof of their own legal basis, amount, and link to the injury.

Source: https://law.justia.com/cases/california/supreme-court/2011/s179115/

## Sources

- [Civil Code § 3333 — Compensation for harm](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=3333.)
- [CACI No. 3900 — Tort damages (2026 edition)](https://courts.ca.gov/system/files/file/judicial_council_of_california_civil_jury_instructions_2026.pdf)
- [Howell v. Hamilton Meats & Provisions, Inc. (2011) 52 Cal.4th 541](https://law.justia.com/cases/california/supreme-court/2011/s179115/)

General information, not legal advice.