What is the impact of a future care costs award for a plaintiff who has been diagnosed with osteoarthritis?

The extent, if any, to which a future care costs award should be adjusted for contingencies depends on the specific care needs of the plaintiff. In some cases negative contingencies are offset by positive contingencies and, therefore, a contingency adjustment is not required. In other cases, however, the award is reduced based on the prospect of improvement in the plaintiff’s condition or increased based on the prospect that additional care will be required. Each case falls to be determined on its particular facts: Gilbert v. Bottle, 2011 BCSC 1389 at para. 253. Here, as the plaintiff has not yet tried certain remedies, I decline to adjust for contingencies; further there was no evidence he was improving. There was only the certainty his osteoarthritis pain would continue.