The following excerpt is from McCarthy v. U.S., 870 F.2d 1499 (9th Cir. 1989):
In computing lost earnings, the district court may not normally use the historical increases in wages to adjust the lost stream of income. As we pointed out in Trevino, "the growth rate of wages includes a component attributable to pay increases due to increased education, age and maturity, and increases in productivity, as well as a component attributable to inflation, the difference between the interest rate ... and the rate of growth of wages understates the real interest rate by whatever proportion of the growth rate of wages is not attributable to inflation." Trevino v. United States, 804 F.2d at 1518 (emphasis in original).
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