Issue: Under Wyoming law, which are the proper life expectancy tables to use in a wrongful death action?
|Area of Law:||Litigation & Procedure, Personal Injury & Negligence|
|Keywords:||Wrongful death action; Life expectancy tables|
|Cited Cases:||314 P.2d 948|
The legislature has adopted life expectancy tables which reflect life expectancy in this state. The legislature could easily update or change these statutes. It has not done so.
In Muir v. Haggerty, also a wrongful death action, the Wyoming Supreme Court rejected tables compiled based on what the court termed a puzzling computation. Muir v. Haggerty, 77 Wyo. 280, 314 P.2d 948, 951 (1957). The court then constructed its own tables of the decedent’s future contribution based on the Wyoming statutes for present worth discounts. Id. This indicates a strong preference for the tables promulgated by the Wyoming legislature.