Novko v. State of New York

After a state trooper's vehicle struck Novko, a self-employed dairy farmer, causing spinal injuries, Novko changed his storage and baling systems, remodeled buildings, hired additional help, and shifted toward management to reduce physical strain; the trial court, having found the state fully liable, nonetheless denied earning-capacity damages and limited pain-and-suffering damages to about one year, reasoning Novko should have taken a less strenuous job like equipment sales.