Vlahos v. Sentry Insurance

I respectfully dissent. It is my view that the undisputed evidence requires a finding that Angie Vlahos is entitled to lost income benefits under OCGA § 33-34-4 (a) (2) (B).

“To recover benefits for ‘loss of income or earnings during disability’ pursuant to OCGA § 33-34-4 (a) (2) (B), an insured is required merely to establish with ‘reasonable certainty’ the fact and amount of such lost income or earnings, and this he may accomplish either by showing that he previously had accepted an offer of income-generating employment for the period in question or by showing ‘a continuous pattern of…