In Wal-Mart Stores, Inc. v. Holland, 956 S.W.2d 590, 599 (Tex. App.--Tyler 1997), rev'd on other grounds, 1 S.W.3d 91, 42 Tex. Sup. Ct. J. 875 (Tex. 1999) that court said that "physical impairment, sometimes termed loss of enjoyment of life, encompasses the loss of the injured party's former lifestyle." The Fourteenth District court of appeals in Houston seems to have agreed with the latter view of the Tyler court, holding that "physical impairment, sometimes called loss of enjoyment of life, encompasses the loss of the injured party's former lifestyle." A dissenting opinion in the San Antonio court of appeals contended that loss of enjoyment of life should be categorized as part of mental anguish damages. Santa Rosa Med. Ctr. v. Robinson, 560 S.W.2d 751, 762 (Tex. Civ. App.--San Antonio 1977, no writ) Thus, loss of enjoyment of life has variously been categorized as an element of pain and suffering, mental anguish, or physical impairment.