Conn. Civ. Jury Instr. 3.4-11

The plaintiff claims economic damages for future medical expenses. The plaintiff may recover

damages for future medical expenses if: (1) the plaintiff has established that it is reasonably

probable that the plaintiff will incur future medical expenses for the injuries caused by the

defendant, and (2) there is a reasonable basis to calculate the amount of those expenses.

If you find that the plaintiff has proved, with reasonable probability, that future medical expenses

for care and treatment will be necessary and were caused by the defendant’s negligence, you may

award compensation for those probable future expenses proved in an amount that you find

reasonable giving due consideration to the life expectancy of the plaintiff and evidence from the

plaintiff’s treating doctors. Damages for the future consequences of an injury can never be

forecast with absolute certainty. With respect to such awards, the cost and frequency of past

medical treatment, to the extent you find such cost and treatment to have been reasonably

necessary and caused by the defendant’s conduct, may be used as a yardstick for future expenses

if it can be reasonably inferred that the plaintiff will continue to seek the same form of treatment

in the future as received in the past. To the extent that you do not find that future treatment is

probable or that a regime of past treatment is not helpful to you in determining future treatment,

you may not speculate or guess about future treatment or the costs of such treatment.