Where a plaintiff suffers an unrelated medical condition during a period of work injury incapacity, past economic loss must be reduced for the period the plaintiff would have been unable to work due to the unrelated condition, applying the compensatory principle from Todorovic v Waller. The Baker v Willoughby principle (no reduction for supervening torts) does not extend to supervening events arising from pre-existing medical conditions. A finding that a plaintiff would have worked beyond age 65 requires more than the plaintiff's stated intention; the court must consider the plaintiff's actual health, capacity, and circumstances.
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