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According to Florida case law as of the date of this article, even if a car accident victim is not permanently injured, it is possible that the victim can recover future economic damages:

“We find no reversible error in any of the issues raised by appellant except for the lower court’s giving of a jury instruction to the effect that appellants could not recover future lost earnings or future medical expenses absent the jury’s predicate finding of permanent injury. This instruction was erroneous in light of Auto-Owners Ins. Co. v. Tompkins, 651 So.2d 89 (Fla.1995), which held that future economic damages may be recovered without a finding of permanency when such damages are established with reasonable certainty:
We reject the mandatory permanent injury threshold test for future economic damages and find the appropriate test is to permit the recovery of future economic damages when such damages are established with reasonable certainty. Although a permanent injury is not a prerequisite to recovering future economic damages, it is a significant factor in establishing *1198 the reasonable certainty of the future damages.
Id. at 91. There was sufficient evidence offered by appellants on which the jury could have made some award of future economic damages. See Metrolimo, Inc. v. Lamm, 666 So.2d 552 (Fla. 3d DCA 1995).”

See: Stephenson-Noland v.Nadd, 670 So. 2d 1197 (Fla. Dist. Ct. App. 5th Dist. 1996)

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