Case Overview:
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Appeal:
- The appellants challenged the award for Mr. Huang’s loss of future earning capacity, claiming the trial judge's reliance on statistical averages was speculative and not based on Mr. Huang’s specific circumstances.
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Accident Details:
- In 2015, Mr. Huang, then 19, suffered a mild traumatic brain injury (MTBI) and other injuries, leading to ongoing anxiety, depression, cognitive deficits, and mild headaches.
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Trial Findings:
- The judge found Mr. Huang’s earning potential was adversely affected by the accident.
- Using statistical data, the judge compared potential earnings with post-secondary education (without accident) against high school diploma earnings (with accident), awarding $539,192.
Appellants' Arguments:
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Speculative Damages:
- The award was speculative and not evidence-based.
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Statistical Evidence:
- The judge should have considered Mr. Huang’s unique circumstances over general averages.
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Educational Path:
- Contended that Mr. Huang’s struggles with English and personal factors were not adequately weighed.
Court's Decision:
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Evidence Validation:
- The court supported the trial judge's use of statistical evidence, noting the appellants' initial acceptance of similar methods.
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Future Earnings:
- The judge’s conclusions on Mr. Huang’s educational and vocational prospects were well-supported by evidence and expert testimony.
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Contingencies:
- The judge appropriately accounted for contingencies and rejected the argument that Mr. Huang had a pre-existing inability to learn English.
Outcome: The appeal was dismissed, affirming the trial court’s decision and the award for Mr. Huang’s future loss of earning capacity of $539,192.00.