How an Economic Damages Analysis Is Built

KW Economics supports both plaintiff and defense counsel. The three narratives below are anonymized composites that show how a damages figure is grounded, structured, and tested in three common contexts. They describe method, not specific cases or outcomes.

By Christopher Skerritt, M.Ed., MBA, Chief of Economic Services · Reviewed

Our work is retained by plaintiff attorneys, defense attorneys, insurers, and businesses. We do not advocate for either side - our role is to apply accepted economic methods to the records in the case and produce an analysis that can be examined figure by figure. The narratives below are illustrative and contain no client-identifying details; any resemblance to a particular matter is coincidental.

Built to be defensible

Whatever the loss, the analysis is held to the same standard - so each figure holds up under examination, not just on paper.

Lost Earnings in a Traumatic Brain Injury Matter

Context

A skilled tradesperson in mid-career sustained a traumatic brain injury in a motor vehicle collision. After rehabilitation the person returned to part-time work in a lower-paid position, and the treating record and a vocational opinion agreed that a return to the prior trade was not expected.

Approach

  1. Earnings base established from several years of tax returns, W-2 forms, and union wage and benefit records, with overtime and shift differentials examined separately rather than averaged in
  2. But-for earnings projected over the person's statistical worklife with wage growth drawn from published government series for the occupation and region, and employer-paid benefits valued as a share of wages
  3. Post-injury earnings path built from the actual part-time wage and the vocational opinion on the person's remaining capacity, then offset against the but-for stream year by year
  4. Future net losses discounted to present value under the discount rate convention that applies in the venue, with a sensitivity table showing the effect of alternative worklife and growth assumptions

What the analysis delivered

The report gave counsel a schedule in which every year's loss traced to a stated earnings base, growth rate, and post-injury wage, so a mediator could see exactly what moved the number. Because the sensitivity table had already bracketed the worklife and growth assumptions, a critique of the report has to engage a specific input rather than the method.

About this case type

Lost Profits in a Commercial Contract Dispute

Context

A regional distributor claimed that a supplier's early termination of an exclusive supply agreement caused lost profits over the remaining contract term. The distributor had several years of financial statements before the termination and a partial recovery from substitute suppliers afterward.

Approach

  1. But-for revenue projected from the distributor's own pre-termination sales history and the volume commitments in the agreement, tested against the growth of the market over the same period
  2. Avoided costs identified from the general ledger so that only the incremental costs the distributor no longer incurred were deducted, leaving lost profit rather than lost revenue
  3. Mitigation credited from the actual substitute-supplier results, with the transition costs of establishing those relationships treated as part of the loss
  4. Losses over the remaining term discounted to the date of breach and reconciled to the financial statements the parties had exchanged in discovery

What the analysis delivered

The analysis tied every figure to the distributor's own records and the contract, addressed causation and mitigation directly, and separated lost profit from lost revenue. Counsel could present a number whose foundation was visible on the face of the report, and any challenge had to be directed at a stated assumption, such as the growth rate, rather than at an undisclosed method.

About this case type

Business Valuation in a Shareholder Dispute

Context

A minority shareholder in a closely held professional services company sought a buyout after a dispute with the majority owners. The company had stable revenue, an owner-heavy cost structure, and no prior transactions in its shares.

Approach

  1. Financial statements normalized for owner compensation above market, personal expenses run through the business, and non-recurring items, so that the earnings stream reflected what a buyer would expect to receive
  2. Income approach applied to the normalized cash flow with a capitalization rate built up from published risk data, cross-checked against a market approach using transactions in comparable private companies
  3. The standard of value that applies to a buyout under the state's law identified with counsel before the analysis, so that discounts for lack of control and marketability were addressed under that standard rather than assumed
  4. Value reported as of the date the parties agreed on, with a reconciliation of the approaches and a sensitivity analysis on the capitalization rate and the owner compensation adjustment

What the analysis delivered

The report gave the parties a documented value with each normalization adjustment explained and the discount question framed under the governing standard of value rather than left to argument. Both sides had a common basis from which to negotiate, and the reconciliation showed how much of the range came from each approach.

About this case type

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