Lost Future Wages in a Maryland Personal Injury Case

In Maryland, the law presently is that in a personal injury action, as well as in a wrongful death action, any damages awarded for loss of future earning capacity must be reduced to present value. Walston v. Sun Cab Co., 267 Md. 559, 574-75, 298 A.2d 391 (1973) (wrongful death action); Dennis v. Blanchfield, 48 Md.App. 325, 333, 428 A.2d 80 (1981), modified on other grounds sub. nom., Blanchfield v. Dennis, 292 Md. 319, 438 A.2d 1330 (1982) (personal injury action). We believe, damages awarded for loss of future earning capacity must be reduced to present value. The situation requires employing an accountant or economist to reduce a claim for future lost wages to a present value. The situation is encountered where you can expect your client can return to their prior employment but they will not be able to do so for some identifiable future period of time.