A trial judge assessing future economic loss for a young worker errs in treating pre-accident work patterns and income as determinative of future earning capacity, particularly where the evidence shows the worker was likely to progress to higher-earning work. Post-accident earnings increases do not negate a claim for substantial loss of future earning capacity where the plaintiff would have earned even more but for the injury. A percentage of whole person impairment calculated under WorkCover Guidelines does not provide real insight into the appropriate level of non-economic loss.
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