Life care planner
Expert class library · Personal injury · Plaintiff side
Projects the future medical care, equipment, therapy, and attendant services an injured person will need over a lifetime and prices each item. Provides the cost foundation that a forensic economist then reduces to present value, so the plan's medical support largely determines its admissibility.
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Questions this testimony turns on
- What future medical care, equipment, and services will the plaintiff probably need, and for how long?
- Is each item in the plan supported by a treating or examining physician's recommendation?
- What do those items cost in the plaintiff's community?
- Does the plan include treatments that are merely possible rather than reasonably probable?
Methods
- Medical needs assessment
- Future care cost projection
- Treating physician consultation
- Life expectancy inputs
How the testimony is attacked
- Items not tied to a physician's recommendation. Defendants argue the planner invented care needs without medical support. In Block v. Woo Young Medical the court admitted the plan because it rested on the treating surgeon's recommendations, medical records, and an interview of the plaintiff.
- Contingent or speculative future treatment. Defendants seek to strike care the physician says might be needed if earlier treatment fails. In Anders v. Hercules Offshore the court denied exclusion before trial but warned that costs would be admitted only for treatment the plaintiff will probably need, not treatment he might need.
- Lack of certification or delegated work. Opponents argue the witness is not a certified planner or had others prepare plans. In Hernandez v. Crown Equipment the court found decades of rehabilitation and case management experience sufficient and left delegation to cross-examination.
- Preliminary or incomplete plan. Defendants attack a plan labeled informal or preliminary. The Hernandez court held that a plan limited to the most concrete items was reliable for the figures it provided.
- Testimony beyond the planner's expertise. Defendants argue a non-physician planner cannot describe the plaintiff's medical condition. In Guzman-Fonalledas v. Hospital Espanol Auxilio Mutuo the court held the planner's training and experience qualified her to discuss the condition as reflected in the records and the expected costs, with overreach left to cross-examination.
- Costs tied to an excluded condition. A plan that prices care for a condition the court has excluded from damages, without separating it from care the injury requires, is open to exclusion. In Santos-Arrieta v. Hospital Del Maestro the plaintiffs' plan was excluded on that ground.
What the public record shows
Courts have filed at least 14 opinions since 2015 that discuss this class of testimony and cite Daubert or Rule 702, as of October 4, 2026. 6 rulings that show how courts handle this class of testimony:
| Outcome | Case | Court | Year | Why |
|---|---|---|---|---|
| Exclusion reversed | Povrzenich v. Ripepi257 A.3d 61 | Pa. Super. Ct. | 2021 | The Superior Court held it was an abuse of discretion to bar a nurse life care planner from costing a kidney transplant patient's future care because she had never treated such a patient, holding that the gap went to weight because a physician supplied the care and her task was to research and tabulate its cost, and ordered a new trial on future medical expenses. |
| Sent back for review | Santos-Arrieta v. Hospital Del Maestro, Inc.14 F.4th 1 | 1st Cir. | 2021 | After the plaintiffs' life care plan was excluded for costing care for autism, which the court had ruled out as a source of damages, the district court struck the defense planner's testimony after the verdict. The First Circuit vacated, holding the issue had not been raised in the Rule 50 motions, remanded for a ruling on a new trial, and noted concerns that the planner had based his plan on the child's needs rather than the diagnosis. |
| Admitted | Condon v. St. Alexius Medical Center2019 ND 113 | N.D. | 2019 | The North Dakota Supreme Court upheld admitting a life care plan where a physician testified to a reasonable medical probability that the care it recommended was medically necessary, even though he also called the plan a recommendation. |
| Admitted | Guzman-Fonalledas v. Hospital Espanol Auxilio Mutuo308 F. Supp. 3d 604 | D.P.R. | 2018 | The court held that a certified life care planner with long rehabilitation experience was qualified to testify about the plaintiff's condition as shown in the medical records and her expected life care expenses. |
| Limited | Anders v. Hercules Offshore Services LLC311 F.R.D. 161 | E.D. La. | 2015 | The court declined to exclude the plaintiff's life care plan before trial but ruled that the planner and economist could testify only to costs of treatment shown to be probably necessary, not treatment that might be needed. |
| Admitted | Hernandez v. Crown Equipment Corp.92 F. Supp. 3d 1325 | M.D. Ga. | 2015 | The court admitted the plaintiffs' future medical cost testimony from an uncertified but experienced planner, finding her preliminary plan reliable for the items it covered, and admitted the economist who relied on it. |
Each case links to the free opinion text on CourtListener.
In federal court: amended Rule 702
In federal court, since December 1, 2023, Rule 702 says expressly that the party offering an expert must show the court it is more likely than not that the testimony meets each requirement: that it rests on sufficient facts or data, uses reliable methods, and reflects a reliable application of those methods to the case. Questions about the basis of an opinion are no longer automatically matters of weight for the jury. For how the circuits have applied the amendment, see the Rule 702 tracker, which follows each court of appeals; for what that means for preparing or attacking this class of expert, see the guide on amended Rule 702.
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Updated October 4, 2026. How this page is built: rulings are found by searching court opinions on CourtListener. The summaries are written by AI working from the full text of each opinion, and every citation and link is checked automatically. Outcomes are labelled by what the court did with the expert’s testimony. No individual expert is named. This page summarises public decisions for orientation and is not legal advice; read the opinion before relying on any ruling. Spotted an error? Tell us.