1069 - 1732

Catastrophic claims - life expectancy

Anthony Burton v Guy Francis Kingsbury - High Court of Justice 13 September 2007

Anthony Burton, who was 18 at the time, was the front seat passenger in a car being driven by his friend, Guy Kingsbury, near Waterlooville, Hampshire. His girlfriend, Jennifer Haynes, who is now his wife, was the back seat passenger. They were all wearing seat belts. The car crossed 4 lanes of traffic and rolled twenty feet down a bank. Mr Burton was trapped in the car, suffering catastrophic injuries. He was rendered a C4 quadriplegic, wheelchair dependent and was unable to use any part of his body below his shoulders, but he survived the accident with his mental capacity intact. Liability was admitted shortly before trial, leaving the main areas of quantum in dispute.

Mr Burton was awarded £227,000 for pain and suffering and loss of amenity. On all the evidence he was expected to live until he was 66 years of age, a further 41 years beyond his current age. The medical experts looked at the epidemiological research and literature in relation to quadriplegics and then at the medical history and prognosis for Mr Burton to assess his life expectancy in comparison with the average for a man of his age set out in Table 1 of the Ogden Tables which deals with 'Impaired Lives'. Given that mortality had already been taken into account in assessing his life expectancy, it was held that using Table 1 again to establish the appropriate multiplier to discount damages for future cost or care and other future losses was inappropriate as it would involve a double discount. It was held more appropriate to use Table 28 which deals with Multipliers for pecuniary loss for term certain to establish an appropriate multiplier which was fixed at 25.78, resulting in a difference of some £40,000.

Following the accident, Mr Burton purchased a bungalow with a garden, indoor swimming pool and existing separate annex for the carer, for himself, his wife who was also involved in the road accident and their child, conceived and born post accident. As regards future care and case management it was held that the most appropriate care regime for Mr Burton involved, a flexible '4 man team' approach with 2 carers being present for 4 hours per day totalling almost £112,000 per year. This allowed for 18 hours a day for daytime care with an additional provision for a night sleeper for 337 nights a year, waking nights in times of illness, national insurance, annual or sickness leave, recruitment and payroll costs and additional food costs and community access fund. In the circumstances of the present case the court decided not to award periodical payments but did consider that it was appropriate in relation to the cost of future care and case management.

As regards the extent to which the award of damages in respect of future care required to be reduced or adjusted to reflect the funding for care which Mr Burton received and would continue to receive from the state, the court considered the socio-political question as to whether a wrongdoer should in fact benefit from the state funding his victim's care. Following the recent Court of Appeal decision in Crofton v NHS Litigation Services [2007] 1 WLR 923 and in the circumstances of the case it was held that state funding could not be ignored. Evidence was heard from the Council that their current policy regarding funding for care took account of the capital income of any particular client and any sums awarded by way of damages. However, it was emphasised that this policy could change in the future. With this background in mind, the court held that the defendant should pay whatever proportion of the annual payment which the court had awarded in respect of care and case management and was not funded by the state. The court held that there would require to be safeguards in place as regards timing of payments and the parties were at liberty to come back to the court for further direction.

Mr Burton was awarded sums in respect of occupational therapy and aids, physiotherapy and equipment and hydrotherapy and swimming pool. The court heard evidence from both sides that Mr Burton would benefit from regular sessions of hydrotherapy. The court held that it had been reasonable for Mr Burton to have bought the property he did and that there was no basis for concluding that he had paid an excessive price for it. An award of interest was also payable on the difference between the figure paid for the house and the much lower figure he would have paid for an ordinary property had he not suffered the accident. He also recovered the adaptation costs of the accommodation and running cost of the swimming pool in full. As regards future loss of earnings, it was held that but for the accident Mr Burton would have earned about £16,800 per year. Applying a multiplier of 20 gave a total award of £336,000. In addition Mr Burton was entitled to special damages for items such as loss of earnings, family care, equipment, insurance and travelling expenses. In all, he was awarded damages of over £6,000,000.

At present we have no Scottish authorities dealing with the issue of care expenses and state funding. However, in the last few weeks, Lord McPhail in Argyll and Bute Council v Judicial Review of a decision of the Scottish Public Services Ombudsman, held that it was not possible to interpret the Scottish legislation regarding free personal care for the elderly as obliging a local authority to make payments for personal care that was not provided by them. It will therefore be interesting to see how this socio-political issue is dealt with in Scotland.

Contributed by Tanya Gordon

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