Law School Case Brief
Feldman v. Allegheny Airlines, Inc. - 524 F.2d 384 (2d Cir. 1975)
The term "personal living expenses" of a decedent is defined in Connecticut law as those personal expenses which, under the standard of living followed by a given decedent, it would have been reasonably necessary for him to incur in order to keep himself in such a condition of health and wellbeing that he could maintain his capacity to enjoy life's activities, including the capacity to earn money.
On June 7, 1971, an Allegheny Airlines flight crashed in fog while approaching New Haven Airport. Nancy Feldman, a passenger, died, in the crash. Defendant Allegheny conceded liability, and the parties submitted the issue of damages to Judge Blumenfeld of the United States District Court for the District of Connecticut. The court awarded $444,056 damages to plaintiff widower, Reid Laurence Feldman, as administrator of the estate of his late wife in plaintiff's wrongful death lawsuit. The airline appealed.
Did the trial court err in the determination of the award for damages?
The court held that while the trial judge's determinations were correct for the most part, certain calculations needed to be re-examined. Specifically, the trial judge erred when he concluded that decedent's anticipated earnings during those years in which she would be engaged in childcare would be equal to her anticipated earnings during other years, as her earnings would be lower during the time that she raised children. The trial judge also underestimated the actual costs of food, shelter, clothing, and health care to be deducted from decedent's anticipated earnings. Remand was therefore required.
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