In Estrada v. Dillon 44 S.W.3d 558, 44 Tex. Sup. Ct. J. 613 (Tex. 2001) the Court considered whether a court of appeals had properly conducted a factual sufficiency review of evidence of damages due to physical impairment. The jury had awarded damages for past physical pain and mental anguish, past loss of earnings, and past medical care. The jury did not award any damages for future physical pain and mental anguish, future medical care, future loss of earning capacity, past or future physical impairment, or past or future disfigurement. The court of appeals reversed the trial court's judgment and remanded the case, concluding that the failure to award any damages for past physical impairment required a new trial. The court of appeals did not reach the plaintiffs' contention that the failure to award damages for other elements also required reversal. The Court found no error in the factual sufficiency review, but we did hold that the court of appeals erred in remanding for a new trial solely on damages. The Court did not analyze in any detail the history of physical impairment, but instead focused on whether a jury must award damages for past physical impairment if there was objective evidence of an injury. The Court "assumed" that the defendants' definition of physical impairment was correct. The Court said: "Assuming that [the defendants] are correct that evidence of physical impairment must focus on restriction of activities caused by the injury, the court of appeals' analysis in this case is not inconsistent with that focus. The court of appeals did not hold that proof of objective injury alone establishes physical impairment." Id.