A minor plaintiff's economic claim is built without the record that anchors every adult claim, the earnings history, so the economist projects what the child would likely have earned from the education the record supports and the published earnings of people with that education, then carries the projection across a worklife that has not yet begun. The claim consists of the lost earning capacity, the fringe benefits that would have come with it, the household services the child will be unable to perform as an adult, and the present value of the incremental future care, each measured against the path the child was on before the injury. This guide explains how the educational path is established, how the earnings base is built from published data rather than from records, why the long horizon makes the growth and discount assumptions decisive, how the care costs and the parents' claims are separated from the child's, and what each side should expect to see in a report.
An adult's lost earnings claim starts from the wage forms, the tax returns, and the pay records, and the dispute is over how to project them. A child has none of those, and the claim is for lost earning capacity in its purest form: the stream of earnings the child was on course to earn over a working life that had not started, measured against whatever the child can now be expected to earn. The lost earnings versus lost earning capacity comparison explains why the distinction matters; for a minor plaintiff it is the whole claim, because there is no actual earnings history to lose.
The components are otherwise the familiar ones. The personal injury analysis carries the lost earning capacity, the fringe benefits that attach to it, the household services the child will be unable to perform as an adult, and the present value of the incremental future care the injury requires over the child's life. What changes is the evidence each component rests on: published data in place of records for the earnings, the medical opinions for the horizon and the care, and the family's circumstances for the path the child was on.
Earnings in the published data vary more with education than with any other single characteristic the economist can observe, so the first question is what education the child would likely have completed. The evidence is indirect but not thin. The parents' education and occupations are the strongest predictors in the published research on attainment, and school records, grades, standardized test results, and any special education or gifted placement add to the picture for a child old enough to have them. For an infant, the family's education and circumstances are most of the evidence, and the report says so rather than assuming a particular degree.
The economist does not pick a single path and assert it. The usual practice is to present the loss under more than one educational outcome, for example a high school diploma, some college, and a bachelor's degree, each with its own earnings profile, and to state which outcome the record most supports and why. Where the record contains opinions from an educational or psychological expert on the child's prospects before and after the injury, the economist builds on those opinions rather than forming an independent view, in the same way that a malpractice report builds on the causation opinions. The lost earnings guide describes the base an adult claim uses, and the educational path is what replaces it here.
With the educational path stated, the earnings base comes from the published series on earnings by age, sex, and educational attainment, which give the median or mean earnings of full-time workers at each stage of a career. The age-earnings profile method describes how those series are used to shape an earnings stream that rises through the early and middle career and flattens later, which matters more for a child than for an adult, because the whole career is being projected rather than the remainder of one. The report states which series, which year, and which measure was used, and whether the figures are for all workers or full-time workers only.
Two choices in the base are contested often enough to be named. The first is whether to use the national series or the series for the region where the child will likely live and work, and the report should say which and why, since wage levels differ across the country. The second is whether to apply sex-specific earnings and worklife tables or combined tables; several venues have limited the use of sex-based or race-based tables in projecting a child's earnings, and the report should present the figures on the basis the venue directs and note the alternative where it does not. In a personal injury matter venued in New York, or anywhere, counsel should settle that question before the report is written.
A child's worklife has not begun, so the horizon runs from the expected age of labor force entry, which follows from the educational path, to the worklife expectancy the published tables give for a person of that education, as the worklife expectancy method explains. The fringe benefits run with the earnings over the same horizon; the household services and the care costs run over the life expectancy the medical evidence supports, which the injury may have changed. Each stream has its own start and end, and the report shows them.
The length of the horizon is what makes a minor plaintiff's claim sensitive to the growth and discount assumptions in a way an adult's claim is not. Earnings that begin in a decade or more and run for several decades after that are grown at a wage growth rate and discounted at an interest rate over the entire span, and a small change in the difference between the two rates changes the present value by a large proportion. The present value method and the present value versus total offset comparison explain the choices, and a report for a child should show the sensitivity of the total to the net discount rate so that the trier of fact can see what the assumption is worth.
Where the injury leaves permanent care needs, the care plan prepared by the professional who authors such plans lists each item with its frequency and duration, and the cost projection prices and discounts each item over the horizon the medical evidence supports. For a child the horizon is long, the items change as the child grows, and the plan usually sets out phases, childhood, adolescence, and adulthood, each with its own items; the economist projects each phase separately and the report shows them in sequence. The household services the child would have performed as an adult, for the child's own household, are valued from the time-use data and the replacement cost series like any other household services claim, beginning at the age the data show such work starting.
The parents' claims are separate from the child's and are kept separate in the report. The parents' lost earnings while caring for the child, the care they have provided themselves and will provide in place of paid care, and the past medical expenses they have paid belong to the parents under most frameworks, run until the child reaches majority or beyond as the venue allows, and are measured from the parents' records. The child's claim is for the child's own lost earning capacity, benefits, household services, and future care; a report that merges the two has made an error the opposing economist will find on the first schedule.
A report for a minor plaintiff cannot be tested against an earnings history, so it is tested against its own transparency. Each side should expect to see the educational outcomes considered and the evidence for the one the report favors; the published series behind each earnings profile, by name, year, and measure; the labor force entry age and the worklife horizon with the table they come from; the growth and discount rates with their sources; the medical opinions each horizon rests on; and the loss under each scenario the record supports. A report that presents a single educational outcome, a single set of rates, and a single total has made every contested choice silently, and the reading guide explains how an opposing economist takes such a report apart.
The defense economist's work is the same analysis with the same evidence, and the usual differences are in the educational path, the choice of tables, and the net discount rate rather than in the method. Where the plaintiff's report has assumed a degree the record does not support, or applied a growth rate without a matching discount rate, the defense report shows the correction and its effect. Because a minor's settlement or judgment is usually subject to court approval and is often structured, both sides have reason to present the loss in a form the court can follow from the educational assumption to the present value, and the report is written for that reader.
From the education the record supports and the published earnings of people with that education. The parents' education and occupations, the school records, and any expert opinions on the child's prospects establish the likely educational path; the published series on earnings by age and attainment supply the earnings profile for that path; and the worklife tables for that education supply the horizon. The report presents the loss under more than one educational outcome and states which the record favors.
Because the earnings begin years in the future and run for decades after that, so every dollar is grown and discounted over a long span. A small change in the difference between the growth rate and the discount rate compounds across the whole horizon and moves the present value by a large proportion, which is why a report for a child shows the total under more than one net rate.
They are separate claims and are reported separately. The parents' lost earnings while caring for the child, the value of the care they provide in place of paid care, and the medical expenses they have paid belong to the parents under most frameworks. The child's claim is for the child's own lost earning capacity, fringe benefits, household services, and future care.
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