Here's the First District in Stift v. Lizzadro on the issue of whether expert testimony is needed to prove damages for future pain and suffering:
[L]ay testimony will only suffice to warrant a jury instruction on future pain and suffering when the existence of the plaintiff's ongoing pain and suffering would be readily apparent to a lay jury from the nature of the injury. See Maddox, 265 Ill. App. 3d at 1010-11, 639 N.E.2d at 167. In Maddox, the court effectively articulated and analyzed this rule as follows:
Where future pain and suffering can be objectively determined from the nature of an injury, the jury may be instructed on future pain and suffering based on lay testimony alone or even in the absence of any testimony on the subject. Where future pain and suffering is not apparent from the injury itself, or is subjective, the plaintiff must present expert testimony that pain and suffering is reasonably certain to occur in the future to justify the instruction. Maddox, 265 Ill. App. 3d at 1011, 639 N.E.2d at 167.
The Stift court held that the trial court had properly refused the plaintiff's instruction on future pain and suffering where the plaintiff's pain was not readily apparent to the jury and the expert's testimony about future pain and suffering was ambiguous.