The factors relevant to assessing the value of lost future earning capacity were set out in the decision in Brown v. Gorlaiy (1985) 26 B.C.L.R. (3d) at paragraph 8: 1. The plaintiff has been rendered less capable overall from earning income from all types of employment; 2. The plaintiff is less marketable or attractive as an employee to potential employers; 3. The plaintiff has lost the ability to take advantage of all job opportunities which might otherwise have been open to him, had he not been injured; and 4. The plaintiff is less valuable to himself as a person capable of earning income in a competitive labour market.
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