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Kaczkowski v. Bolubasz, 491 Pa. 561, 421 A.2d 1027, 21 A.L.R.4th 1

Facts

The case arose from an automobile accident in which Eric K. Kaczkowski was a passenger and was fatally injured. At the original trial, the jury found the defendant liable, and a retrial was held to determine damages. The decedent was a 20-year-old male attending the Institute of Computer Management, and testimony was presented regarding his potential future earnings. The trial court excluded expert testimony on the impact of inflation and productivity on future earnings, leading to a jury verdict of $30,000, which the plaintiff contested.

The suit arose from an automobile accident in which the decedent, Eric K. Kaczkowski, was riding as a passenger in a vehicle operated by appellee.

Issue

Whether the trial court erred in excluding reliable economic testimony showing the impact of inflation and increased productivity on the decedent's future earning power.

The issue raised by appellant is whether the trial court erred in excluding reliable economic testimony showing the impact of inflation and increased productivity on decedent's future earning power.

Rule

In awarding damages for lost future earnings, the court shall consider the victim's lost future productivity and presume that future inflation is equal to future interest rates, thus eliminating the need to discount future lost earnings.

In this Commonwealth, we have consistently held that damages are to be compensatory to the full extent of the injury sustained.

Analysis

The court found that the trial court's exclusion of expert testimony regarding inflation and productivity was erroneous. It emphasized that both factors are integral to accurately calculating lost future earnings and that the previous approach, which disregarded these elements, was outdated and inconsistent with the realities of the economy. The court concluded that reliable economic data should be admissible to inform the jury's assessment of future earnings.

Despite the uninformed belief of the Haven's court, inflation and productivity factors are not speculative and are capable of definition and prediction by economic experts.

Conclusion

The Supreme Court reversed the lower court's decision and remanded the case for a new trial on the damages question, allowing for the inclusion of expert testimony on inflation and productivity.

Reversed and remanded for new trial as to damages question.

Who won?

The plaintiff prevailed in the case because the Supreme Court recognized the need to consider inflation and productivity in calculating lost future earnings, which had been improperly excluded in the lower court.

The Supreme Court reversed the lower court's decision and remanded the case for a new trial on the damages question, allowing for the inclusion of expert testimony on inflation and productivity.

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