How have courts determined the permanence of a plaintiff's injury is determined after a bench trial?

In Fraysier v. United States, 766 F.2d 478 (11th Cir. 1985), the district court's determination that the permanence of plaintiff's injury was based on newly discovered evidence was made after trial. Id. at 480-481. In United States v. Alexander, 238 F.2d 314 (5th Cir. 1956), the district court's determined after a bench trial that when plaintiff's claim was filed, he did not know his shoulder injury would require surgery. Id., at 316. And in Michels v. United States, 31 F.3d 686 (8th Cir. 1994), the district court determined that plaintiff's increased damage claims was based on newly discovered evidence after a bench trial. Id., at 687.