Jones & Laughlin Steel Corp. v. Pfeifer
United States Supreme Court
462 U.S. 523 (1983)
Pfeifer (plaintiff) was permanently injured working for Jones & Laughlin Steel (defendant) and could only do light, minimum-wage work afterward. The trial court calculated his damages by multiplying his injury-time wage by his estimated remaining working years, subtracting his potential minimum-wage earnings and prior compensation payments, adding $50,000 for pain and suffering, but declined to separately adjust for future inflation or discount to present value, reasoning under state law that the two factors would offset each other.
Whether, in calculating damages for lost future income, a court can account for foreseeable promotions, foreseeable industry growth, and estimated future price inflation, offset by an estimated market interest rate reflecting a safe investment.