Legal Memorandum: Wrongful Death and Life Expectancy Tables

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
Jurisdiction: Wyoming
Cited Cases: 314 P.2d 948
Cited Statutes: None
Date: 02/01/2001

           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.


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