Lost household services are regularly claimed in actions involving personal injury or wrongful death. Economic damages experts will usually include calculations of the economic value of services, chores and assistance that the injured or deceased person would have provided to the household. The Dollar Value of a Day (2017) study generally groups these tasks into two subgroups: Household Production and Caring & Helping. There is, however, a third element to consider: Nighttime Protection and Care services. Nighttime Protection and Care services are those services that are immediately available during the night to respond to security emergencies and or to render assistance or care to household members. As explained by Landsea (2014), although this is a passive service, it has value, as do other household services which might be considered as active. Landsea described it this way: “The physical presence in the household of the service provider for the rendering of security, protection, and assurance of active services when needed.” This element of Household Services is one that has been admitted by courts and validated by juries but is often overlooked by forensic practitioners.