Stringham v. United Parcel Service, Inc.

181 Ill. App. 3d 312, 130 Ill. Dec. 81, 536 N.E.2d 1292 (1989)

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Stringham v. United Parcel Service, Inc.

Illinois Appellate Court
181 Ill. App. 3d 312, 130 Ill. Dec. 81, 536 N.E.2d 1292 (1989)

  • Written by Tammy Boggs, JD

Facts

David Stringham was killed in an automobile accident with United Parcel Service, Inc. (UPS) (defendant). Stringham’s estate (the estate) (plaintiff) brought a wrongful-death action against UPS. At trial, the estate’s economic expert, Jack Skeels, testified to the value of Stringham’s projected future earnings. Based on actuarial data, Skeels predicted that Stringham would have continued working a certain number of years if he had lived. Skeels created an age profile of Stringham showing Stringham earning greater wages as he gained years of experience. The wage levels used by Skeels did not account for inflation. Instead, the wage levels were based on a comparison of income levels of workers of different ages at the same point in time. Next, Skeels discounted Stringham’s future earnings using a market interest rate of 7.3 percent minus a rate of 6 percent representing “growth of earnings,” which was essentially the rate of inflation. Skeels thus used a 1.3 percent net discount rate to calculate the present value of Stringham’s future earnings. Based on Skeels’s testimony, the jury awarded the estate $252,631.08. The trial court entered judgment accordingly. UPS appealed, arguing that Skeels’s accounting for inflation during his present-value calculation was improper.

Rule of Law

Issue

Holding and Reasoning (Reinhard, J.)

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