Yes. In a Nevada personal injury case, you can seek compensation for future medical expenses and future rehabilitation costs when the evidence shows those expenses are a natural and probable consequence of the defendant’s wrongful conduct and are reasonably necessary. Hall v. SSF, Inc., 112 Nev. 1384, 930 P.2d 94 (1996); Lerner Shops of Nev., Inc. v. Marin, 83 Nev. 75, 423 P.2d 398 (1967).
This post is educational information about Nevada law, not legal advice. Every case turns on its facts, medical evidence, insurance issues, and deadlines.
What Counts as “Future Medical Expenses” and “Rehabilitation Costs”?
In practice, future medical and rehab damages can include (when supported by the evidence):
- Future surgeries and related hospitalization, anesthesia, follow-up care
- Specialist care (orthopedics, neurology, pain management, etc.)
- Diagnostic testing (MRI, CT, EMG, X-rays) ordered in the future
- Physical therapy, occupational therapy, speech therapy
- Chiropractic care or other conservative care if medically supported
- Medications (including long-term prescriptions)
- Injections or other recurring procedures
- Mental health treatment (counseling, psychiatry) if tied to the injuries
- Assistive devices (braces, canes, walkers, wheelchairs)
- Prosthetics and future replacements, if applicable
- Home health care, attendant care, or caregiving services
- Vocational rehabilitation and retraining when the injury affects work capacity
The key is that these are not “guesses.” Nevada requires proof that future care is reasonably necessary and connected to the incident. Hall, 112 Nev. 1384, 930 P.2d 94; Lerner Shops, 83 Nev. 75, 423 P.2d 398.
The Core Nevada Legal Standard for Future Medical and Rehab Damages
1) You can recover the natural and probable consequences of a tort
Nevada recognizes the general rule that a successful plaintiff may recover damages for all natural and probable consequences of the defendant’s tortious conduct. Hall, 112 Nev. 1384, 930 P.2d 94; Lerner Shops, 83 Nev. 75, 423 P.2d 398.
2) Future medical expenses must be reasonably necessary
For future medical expenses to be recoverable as a natural and probable consequence, the plaintiff must prove those future medical expenses are reasonably necessary. Hall, 112 Nev. 1384, 930 P.2d 94.
That is the concept that drives almost every “future care” dispute in settlement negotiations, expert discovery, and at trial.
3) When future harm is subjective, expert medical testimony is often critical
Nevada authority reflected in the civil instructions and case law recognizes that when the claimed future consequences (pain, suffering, ongoing symptoms) are subjective in nature, they typically require expert medical testimony to establish reasonable certainty, rather than speculation. State, Univ. & Cmty. Coll. Sys. v. Sutton, 120 Nev. 972, 103 P.3d 8 (2004); Krause Inc. v. Little, 117 Nev. 929, 34 P.3d 566 (2001); Gutierrez v. Sutton Vending Serv., Inc., 80 Nev. 562, 397 P.2d 3 (1964); Paul v. Imperial Palace, Inc., 111 Nev. 1544, 908 P.2d 226 (1995).
Future surgery, future therapy, and future medications are usually proven through a treating physician and, in larger cases, a life care planner supported by medical testimony.
What Evidence Actually Proves Future Medical and Rehab Costs?
To make future expenses “real” instead of speculative, you typically build proof in two layers: (1) medical necessity and (2) cost evidence.
Layer 1: Medical necessity and probability
Common sources include:
- Treating doctor testimony about prognosis and recommended future treatment
- Medical records showing the condition is ongoing and requires continued care
- Imaging or objective findings supporting long-term impairment
- Specialist recommendations (orthopedist, neurologist, surgeon, etc.)
- A life care plan grounded in physician recommendations
If the defense produces conflicting medical testimony, the factfinder decides which evidence is more credible. Nevada appellate courts generally will not reweigh conflicting evidence when there is substantial evidence supporting the decision. Hall, 112 Nev. 1384, 930 P.2d 94.
Layer 2: Cost evidence and reasonable valuation
Costs can be supported by:
- Provider estimates, billing histories, and customary charges
- Expert life care planners
- Medical billing experts (when appropriate)
- Pharmacy cost histories for long-term medications
- Durable medical equipment pricing and replacement schedules
A Critical Nevada Procedure Issue: You Must Disclose a Computation of Future Medical Damages
Even if your medical proof is strong, procedural mistakes can hurt future medical claims.
Nevada’s initial disclosure rules require a party to provide a computation of each category of damages claimed. NRCP 16.1(a)(1)(C). The Nevada Supreme Court has addressed how NRCP 16.1 applies to future medical expenses and emphasized the need for a meaningful computation, not vague references to treatment. Pizarro-Ortega v. Cervantes-Lopez, 133 Nev. 261, 396 P.3d 783 (2017).
Practically, this means you should work with your attorney early to make sure future medical damages are properly supported and disclosed in a way that is consistent with Nevada practice.
Practical Tips That Strengthen a Nevada Future Medical and Rehab Claim
- Follow through on recommended care. Gaps can become “reasonable necessity” arguments for the defense.
- Get clear prognosis language from treating physicians when appropriate (ongoing, chronic, permanent, requires future treatment).
- Document functional limitations (work restrictions, activity limits) and how therapy addresses them.
- Track therapy frequency and duration (PT plans often show future course of care).
- Avoid settling too early when future treatment is still uncertain, because a settlement usually resolves all future claims related to the incident.
Nevada Legal Authorities Cited
Nevada statutes and rules
- NRCP 16.1(a)(1)(C)
Nevada case law
- Hall v. SSF, Inc., 112 Nev. 1384, 930 P.2d 94 (1996)
- Lerner Shops of Nev., Inc. v. Marin, 83 Nev. 75, 423 P.2d 398 (1967)
- Pizarro-Ortega v. Cervantes-Lopez, 133 Nev. 261, 396 P.3d 783 (2017)
- State, Univ. & Cmty. Coll. Sys. v. Sutton, 120 Nev. 972, 103 P.3d 8 (2004)
- Krause Inc. v. Little, 117 Nev. 929, 34 P.3d 566 (2001)
- Gutierrez v. Sutton Vending Serv., Inc., 80 Nev. 562, 397 P.2d 3 (1964)
- Paul v. Imperial Palace, Inc., 111 Nev. 1544, 908 P.2d 226 (1995)
If you need assistance with your personal injury case, don’t hesitate to contact Friedman Injury Law.
Friedman Injury Law
375 N. Stephanie St., Ste. 1411
Henderson, NV 89014
P: (702) 970-4222
W: blakefriedmanlaw.com