Is a plaintiff entitled to recover the value of an actuarial expert’s calculation of unpaid household production of goods and services?
Manitoba, Canada
The following excerpt is from Lyne v. McClarty, 2001 MBQB 88 (CanLII):
In Braun Estate v. Vaughan, [2000] M.J. No. 63, our Court of Appeal upheld the decision of the trial judge who relied upon the calculations made by the actuarial expert called by the plaintiff to determine “unpaid household production of goods and services”. The calculations were based on a replacement wage approach. Although replacement services were not engaged, the plaintiff was entitled to recover the value of the loss so determined.
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