When medical malpractice causes a miscarriage or a stillbirth, the New York mother can now sue for her emotional trauma and suffering, even though she suffered no physical injury. What will courts award for such anguish and misery suffered by a mother? In New York, it appears to be $1 million dollars, Ferreira v. Wychoff Med. Ctr., 81 A.D.3d 587 (2d Dep’t 2011), but worth $100,000 in Louisiana and $200,000 in Texas. New York Times, Aug. 24, 2011, p. A-1.