Cook v. Cook

In response to the certified question presented in this' case, the majority opinion has held that a negligently injured plaintiff may recover for the loss of future wages that are a direct consequence of an injury, without showing that the injury itself was permanent. I concur in this result. I have chosen to write separately because I believe the majority opinion should have explained the technical differences between the legal theories of “lost earning opportunity,” “lost or impaired earning capacity,” and “lost future income or wages.”1 While I recognize that many courts tend to use the…