Does a medical expert have to prove a plaintiff is "reasonably certain" to be disabled in the future?

California, United States of America


The following excerpt is from Mandujano v. Johnston, D076422 (Cal. App. 2020):

Moreover, it is not necessary that the medical expert testify a plaintiff is "reasonably certain" to be disabled in the future; rather "[a]ll that is required to establish future disability is that from all the evidence, including the expert testimony, if there be any, it satisfactorily appears that such disability will occur with reasonable certainty." (Mendoza v. Rudolf (1956) 140 Cal.App.2d 633, 637 (Mendoza), italics added.) "In examining the sufficiency of the evidence to support an award of damages, it is not required that we be able to precisely recreate the jury's reasoning. [Citation.] We will

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