R. v. Atherton, 2012 ABCA 305 holds that the exclusion from the forfeiture provisions of the Criminal Code does not extend to a loss of self esteem. One might ask if this ruling extends to all psychological harm from forfeiture -- say the harm caused by losing something of great sentimental value? The Court writes:
 The other arm of his forfeiture appeal has to do with the loss of self-esteem which forfeiture will bring. Given his history, that may well be the fact. But we doubt that that subjective reaction is the sort of disproportionate impact of which Parliament speaks. In any event, this blow is caused by deciding to gamble his last big asset on a criminal and dangerous venture or two. The impact may be disproportionate to his financial rewards (actual or maybe even potential, though we do not know the latter). But it is in no way disproportionate to the grave risks which any reasonable person would see that he was taking with his criminal enterprises. We use the plural because of the assorted contents and modifications of this vehicle.