Wis JI-Civil 1835

Question _____ asks you to determine [(parent)s'] [(parent)'s] loss of (child)'s services

resulting from the injuries sustained by (child). The (parents) (parent) of an injured minor

child (are) (is) entitled to the earnings and to the reasonable value of the services which the

minor child was capable of rendering to the (parents) (parent) until the child reaches the age

of 18.

You should award such sum as will reasonably compensate (parents) (parent) for any

loss of income as you are satisfied (minor child) was reasonably capable of earning and for

the loss of the reasonable value of the services to which (parents) (parent) were entitled

during the period of (minor child)'s disability, to date, resulting from injuries received in (the

accident).

If you find that (minor child)'s disability will continue in the future as a natural result

of the injuries sustained in (this accident), you should allow (parents) (parent), and include in

your award, an amount which will fairly and reasonably compensate (them) (him) (her) for

any loss of income (minor child) would have been reasonably capable of earning and for the

reasonable value of the services which (minor child) would have rendered to (parents)

(parent), except for the disability, until (minor child)'s 18th birthday.

While the plaintiff has the burden of establishing loss of future earning capacity, the

evidence relating to this item need not be as exact or precise as evidence needed to support

your findings as to other items of damage. The reason for this rule is that the concept of (loss

of future earning capacity) requires that you consider factors which, by their very nature, do

not admit of any precise or fixed rule. You therefore, are not required in determining the loss

of future earning capacity to base your answer on evidence which is exact or precise but

rather upon evidence which, under all of the circumstances of the case, reasonably supports

your determination of damages.