Life Care Planning Expert Witnesses Discuss Earning Potential and Forecast Modeling for Injured Youth

A 15-year-old African American female was injured at school while operating a piece of machinery and as a result lost partial use of one eye. Suit has been brought against the teacher and school district for negligent supervision and failure to enforce rules and regulations necessary for student safety. The theory being that the teacher and school had a duty to protect and supervise specifically with automobiles and machinery. The plaintiff is demanding damages equal to the resultant loss of earning potential. She retained a life care planning expert and economist to assist with the earnings calculation.

Question(s) For Expert Witness

1. Given certain factors, can you compute the specific earnings potential of this individual?

2. What background do you have in forecast modeling? Elaborate.

3. Can you include factors specific to this individual in your models? For example: scholastic aptitude, family demographic, etc.

Expert Witness Response E-009395

I can assess the earning capacity of the plaintiff. I have extensive experience in forecast modeling and have reviewed numerous cases involving eye injury. I apply the RAPEL model. Since the plaintiff is a teenager and presumably does not have a work history as yet, I would review school records and standardized testing to identify the aptitudes of the plaintiff pre-injury and examine differences in performance post-injury. I would use medical records and/or speak to the medical expert to determine long-term impairments. I would interview the parents to determine the probability of post-secondary education. I would review the accommodation needs the plaintiff may require in school or for future work. Based on that model of identifying the aptitudes and rehabilitation needs I would identify career options, access to employment, and the earning capacity associated with the plaintiff. I would then compare to pre-injury earning capacity.