Jones & Laughlin Steel Corp. v. Pfeifer

delivered the opinion of the Court.

Respondent was injured in the course of his employment as a loading helper on a coal barge. As his employer, petitioner was required to compensate him for his injury under § 4 of the Longshoremen’s and Harbor Workers’ Compensation Act (Act). 44 Stat. 1426, 33 U. S. C. § 904. As the owner pro hac vice of the barge, petitioner may also be liable for negligence under § 5 of the Act. 86 Stat. 1263, 33 U. S. C. § 905. We granted certiorari to decide whether petitioner may be subject to both forms of liability, and also to consider whether the Court of Appeals correctly upheld the trial court’s computation of respondent’s damages. 459 U. S. 821 (1982).

*526 Petitioner owns a fleet of barges that it regularly operates on three navigable rivers in the vicinity of Pittsburgh, Pa. Respondent was employed for 19 years to aid in loading and unloading those barges at one of petitioner’s plants located on the shore of the Monongahela River. On January 13, 1978, while carrying a heavy pump, respondent slipped and fell on snow and ice that petitioner had negligently failed to remove from the gunnels of a barge. His injury made him permanently unable to return to his job with the petitioner, or to perform anything other than light work after July 1, 1979.

In November 1979, respondent brought this action against petitioner, alleging that his injury had been “caused by the negligence of the vessel” within the meaning of § 5(b) of the Act. The District Court found in favor of respondent and awarded damages of $275,881.36. The court held that receipt of compensation payments from petitioner under § 4 of the Act did not bar a separate recovery of damages for negligence.

The District Court’s calculation of damages was predicated on a few undisputed facts. At the time of his injury respondent was earning an annual wage of $26,025. He had a remaining work expectancy of 1214 years. On the date of trial (October 1, 1980), respondent had received compensation payments of $33,079.14. If he had obtained light work and earned the legal minimum hourly wage from July 1, 1979, until his 65th birthday, he would have earned $66,352.

The District Court arrived at its final award by taking 12/4 years of earnings at respondent’s wage at the time of injury ($325,312.50), subtracting his projected hypothetical earnings at the minimum wage ($66,352) and the compensation payments he had received under §4 ($33,079.14), and adding $50,000 for pain and suffering. The court did not increase the award to take inflation into account, and it did not discount the award to reflect the present value of the future stream of income. The court instead decided to follow a decision of the Supreme Court of Pennsylvania, which had held *527 “as a matter of law that future inflation shall be presumed equal to future interest rates with these factors offsetting.” Kaczkowski v. Bolubasz, 491 Pa. 561, 583, 421 A. 2d 1027, 1038-1039 (1980). Thus, although the District Court did not dispute that respondent could be expected to receive regular cost-of-living wage increases from the date of his injury until his presumed date of retirement, the court refused to include such increases in its calculation, explaining that they would provide respondent “a double consideration for inflation.” App. to Pet. for Cert. 41a. For comparable reasons, the court disregarded changes in the legal minimum wage in computing the amount of mitigation attributable to respondent’s ability to perform light work.

It does not appear that either party offered any expert testimony concerning predicted future rates of inflation, the interest rate that could be appropriately used to discount future earnings to present value, or the possible connection between inflation rates and interest rates. Respondent did, however, offer an estimate of how his own wages would have increased over time, based upon recent increases in the company’s hourly wage scale.

The Court of Appeals affirmed. 678 F. 2d 453 (CA3 1982). It held that a longshoreman may bring a negligence action against the owner of a vessel who acts as its own stevedore, relying on its prior decision in Griffith v. Wheeling Pittsburgh Steel Corp., 521 F. 2d 31, 38-44 (1975), cert. denied, 423 U. S. 1054 (1976). On the damages issue, the Court of Appeals first noted that even though the District Court had relied on a Pennsylvania case, federal law controlled. The Court of Appeals next held that in defining the content of that law, inflation must be taken into account:

“Full compensation for lost prospective earnings is most difficult, if not impossible, to attain if the court is blind to the realities of the consumer price index and the recent historical decline of purchasing power. Thus if we recognize, as we must, that the injured worker is *528 entitled to reimbursement for his loss of future earnings, an honest and accurate calculation must consider the stark reality of inflationary conditions.” 678 F. 2d, at 460-461. 1

The court understood, however, that the task of predicting future rates of inflation is quite speculative. It concluded ■that such speculation could properly be avoided in the manner chosen by the District Court — by adopting Pennsylvania’s “total offset method” of computing damages. The Court of Appeals approved of the way the total offset method respects the twin goals of considering future inflation and discounting to present value, while eliminating the need to make any calculations about either, “because the inflation and discount rates are legally presumed to be equal and cancel one another.” Id., at 461. Accordingly, it affirmed the District Court’s judgment.

The Liability Issue

Most longshoremen who load and unload ships are employed by independent stevedores, who have contracted with the vessel owners to provide such services. In this case, however, the respondent longshoreman was employed directly by the petitioner vessel owner. Under § 4 of the Act, a longshoreman who is injured in the course of his employment is entitled to a specified amount of compensation from *529 his employer, whether or not the injury was caused by the employer’s negligence. 2 Section 5(a) of the Act appears to make that liability exclusive. 3 It reads: “The liability of an *530 employer prescribed in section 4 [of this Act] shall be exclusive and in place of all other liability of such employer to the employee . . . 44 Stat. 1426, 33 U. S. C. § 905(a). Since the petitioner was the respondent’s employer and paid him benefits pursuant to §4 of the Act, it contends that §5(a) absolves it of all other responsibility for damages.

Although petitioner’s contention is, indeed, supported by the plain language of §5(a), it is undermined by the plain language of § 5(b). The first sentence of § 5(b) authorizes a longshoreman whose injury is caused by the negligence of a vessel 4 to bring a separate action against such a vessel as a third party. Thus, in the typical tripartite situation, the longshoreman is not only guaranteed the statutory compensation from his employer; he may also recover tort damages if he can prove negligence by the vessel. 5 The second sentence of § 5(b) makes it clear that such a separate action is authorized against the vessel even when there is no independent stevedore and the longshoreman is employed directly by the vessel owner. That sentence provides: “If such person was employed by the vessel to provide stevedoring services, no such action shall be permitted if the injury was caused by the negligence of persons engaged in providing stevedoring services to the vessel.” If § 5(a) had been intended to bar all negligence suits against owner-employers, there would have been no need to put an additional sentence *531 in § 5(b) barring suits against owner-employers for injuries caused by fellow servants. 6

The history of the Act further refutes petitioner’s contention that § 5(a) of the Act bars respondent’s suit under § 5(b). Prior to 1972, this Court had construed the Act to authorize a longshoreman employed directly by the vessel to obtain a recovery from his employer in excess of the statutory schedule, even though § 5 of the Act contained the same exclusive liability language as today. Reed v. The Yaka, 373 U. S. 410 (1963); Jackson v. Lykes Brothers S.S. Co., 386 U. S. 731 (1967). Although the 1972 Amendments changed the character of the longshoreman’s action against the vessel by substituting negligence for unseaworthiness as the basis for liability, 7 Congress clearly intended to preserve the rights of longshoremen employed by the vessel to maintain such an action. The House Committee Report is unambiguous:

“The Committee has also recognized the need for special provisions to deal with a case where a longshoreman or shipbuilder or repairman is employed directly by the vessel. In such case, notwithstanding the fact that the *532 vessel is the employer, the Supreme Court in Reed v. S.S. Yaka, 373 U. S. 410 (1963) and Jackson v. Lykes Bros. Steamship Co., 386 U. S. 371 (1967), held that the unseaworthiness remedy is available to the injured employee. The Committee believes that the rights of an injured longshoreman or shipbuilder or repairman should not depend on whether he was employed directly by the vessel or by an independent contractor. . . . The Committee’s intent is that the same principles should apply in determining liability of the vessel which employs its own longshoremen or shipbuilders or repairmen as apply when an independent contractor employs such persons.” H. R. Rep. No. 92-1441, pp. 7-8 (1972).

In Edmonds v. Compagnie Generale Transatlantique, 443 U. S. 256, 266 (1979), we observed that under the post-1972 Act, “all longshoremen are to be treated the same whether their employer is an independent stevedore or a shipowner-stevedore and that all stevedores are to be treated the same whether they are independent or an arm of the shipowner itself.” If respondent had been employed by an independent stevedore at the time of his injury, he would have had the right to maintain a tort action against the vessel. We hold today that he has the same right even though he was in fact employed by the vessel.

The Damages Issue

The District Court found that respondent was permanently disabled as a result of petitioner’s negligence. He therefore was entitled to an award of damages to compensate him for his probable pecuniary loss over the duration of his career, reduced to its present value. It is useful at the outset to review the way in which damages should be measured in a hypothetical inflation-free economy. We shall then consider how price inflation alters the analysis. Finally, we shall decide whether the District Court committed reversible error in this case.

*533 In calculating damages, it is assumed that if the injured party had not been disabled, he would have continued to work, and to receive wages at periodic intervals until retirement, disability, or death. An award for impaired earning capacity is intended to compensate the worker for the diminution in that stream of income. 8 The award could in theory take the form of periodic payments, but in this country it has traditionally taken the form of a lump sum, paid at the conclusion of the litigation. 9 The appropriate lump sum cannot be computed without first examining the stream of income it purports to replace.

The lost stream’s length cannot be known with certainty; the worker could have been disabled or even killed in a different, non-work-related accident at any time. The probability that he would still be working at a given date is constantly diminishing. 10 Given the complexity of trying to make an *534 exact calculation, litigants frequently follow the relatively simple course of assuming that the worker would have continued to work up until a specific date certain. In this case, for example, both parties agreed that the petitioner would have continued to work until age 65 (1214 more years) if he had not been injured.

Each annual installment 11 in the lost stream comprises several elements. The most significant is, of course, the actual wage. In addition, the worker may have enjoyed certain fringe benefits, which should be included in an ideal evaluation of the worker’s loss but are frequently excluded for simplicity’s sake. 12 On the other hand, the injured worker’s lost wages would have been diminished by state and federal income taxes. Since the damages award is tax-free, the relevant stream is ideally of after-tax wages and benefits. See Norfolk & Western R. Co. v. Liepelt, 444 U. S. 490 (1980). Moreover, workers often incur unreimbursed costs, such as transportation to work and uniforms, that the injured worker will not incur. These costs should also be deducted in estimating the lost stream.

In this case the parties appear to have agreed to simplify the litigation, and to presume that in each installment all the elements in the stream would offset each other, except for gross wages. However, in attempting to estimate even such a stylized stream of annual installments of gross wages, a trier of fact faces a complex task. The most obvious and most appropriate place to begin is with the worker’s annual wage at the time of injury. Yet the “estimate of the loss *535 from lessened earnings capacity in the future need not be based solely upon the wages which the plaintiff was earning at the time of his injury.” C. McCormick, Damages §86, p. 300 (1935). Even in an inflation-free economy — that is to say one in which the prices of consumer goods remain stable — a worker’s wages tend to “inflate.” This “real” wage inflation reflects a number of factors, some linked to the specific individual and some linked to broader societal forces. 13

With the passage of time, an individual worker often becomes more valuable to his employer. His personal work experiences increase his hourly contributions to firm profits. To reflect that heightened value, he will often receive “seniority” or “experience” raises, “merit” raises, or even promotions. 14 Although it may be difficult to prove when, and whether, a particular injured worker might have received such wage increases, see Feldman v. Allegheny Airlines, Inc., 524 F. 2d 384, 392-393 (CA21975) (Friendly, J., concurring dubitante), they may be reliably demonstrated for some workers. 15

Furthermore, the wages of workers as a class may increase over time. See Grunenthal v. Long Island R. Co., 393 U. S. 156, 160 (1968). Through more efficient interaction among labor, capital, and technology, industrial productivity may increase, and workers’ wages may enjoy a share of that growth. 16 Such productivity increases — reflected in real in *536 creases in the gross national product per worker-hour — have been a permanent feature of the national economy since the conclusion of World War II. 17 Moreover, through collective bargaining, workers may be able to negotiate increases in their “share” of revenues, at the cost of reducing shareholders’ rate of return on their investments. 18 Either of these forces could affect the lost stream of income in an inflation-free economy. In this case, the plaintiff’s proffered evidence on predictable wage growth may have reflected the influence of either or both of these two factors.

To summarize, the first stage in calculating an appropriate award for lost earnings involves an estimate of what the lost stream of income would have been. The stream may be approximated as a series of after-tax payments, one in each year of the worker’s expected remaining career. In estimating what those payments would have been in an inflation-free economy, the trier of fact may begin with the worker’s annual wage at the time of injury. If sufficient proof is offered, the trier of fact may increase that figure to reflect the appropriate influence of individualized factors (such as foreseeable promotions) and societal factors (such as foreseeable productivity growth within the worker’s industry). 19

Of course, even in an inflation-free economy the award of damages to replace the lost stream of income cannot be computed simply by totaling up the sum of the periodic payments. For the damages award is paid in a lump sum at the conclusion of the litigation, and when it — or even a part of it — is invested, it will earn additional money. It has been *537 settled since our decision in Chesapeake & Ohio R. Co. v. Kelly, 241 U. S. 485 (1916), that “in all cases where it is reasonable to suppose that interest may safely be earned upon the amount that is awarded, the ascertained future benefits ought to be discounted in the making up of the award.” Id., at 490. 20

The discount rate should be based on the rate of interest that would be earned on “the best and safest investments.” Id., at 491. Once it is assumed that the injured worker would definitely have worked for a specific term of years, he is entitled to a risk-free stream of future income to replace his lost wages; therefore, the discount rate should not reflect the market’s premium for investors who are willing to accept some risk of default. Moreover, since under Norfolk & Western R. Co. v. Liepelt, 444 U. S. 490 (1980), the lost stream of income should be estimated in after-tax terms, the discount rate should also represent the after-tax rate of return to the injured worker. 21

Thus, although the notion of a damages award representing the present value of a lost stream of earnings in an inflation-free economy rests on some fairly sophisticated economic concepts, the two elements that determine its calculation can be stated fairly easily. They are: (1) the amount that the employee would have earned during each year that he could have been expected to work after the injury; and (2) the ap *538 propriate discount rate, reflecting the safest available investment. The trier of fact should apply the discount rate to each of the estimated installments in the lost stream of income, and then add up the discounted installments to determine the total award. 22

II

Unfortunately for triers of fact, ours is not an inflation-free economy. Inflation has been a permanent fixture in our economy for many decades, and there can be no doubt that it ideally should affect both stages of the calculation described in the previous section. The difficult problem is how it can do so in the practical context of civil litigation under § 5(b) of the Act.

The first stage of the calculation required an estimate of the shape of the lost stream of future income. For many workers, including respondent, a contractual “cost-of-living adjustment” automatically increases wages each year by the percentage change during the previous year in the consumer price index calculated by the Bureau of Labor Statistics. Such a contract provides a basis for taking into account an additional societal factor — price inflation — in estimating the worker’s lost future earnings.

The second stage of the calculation requires the selection of an appropriate discount rate. Price inflation — or more precisely, anticipated price inflation — certainly affects market *539 rates of return. If a lender knows that his loan is to be repaid a year later with dollars that are less valuable than those he has advanced, he will charge an interest rate that is high enough both to compensate him for the temporary use of the loan proceeds and also to make up for their shrinkage in value. 23

At one time many courts incorporated inflation into only one stage of the calculation of the award for lost earnings. See, e. g., Sleeman v. Chesapeake and Ohio R. Co., 414 *540 F. 2d 305 (CA6 1969); Johnson v. Penrod Drilling Co., 510 F. 2d 234 (CA5 1975) (en banc). In estimating the lost stream of future earnings, they accepted evidence of both individual and societal factors that would tend to lead to wage increases even in an inflation-free economy, but required the plaintiff to prove that those factors were not influenced by predictions of future price inflation. See Higginbotham v. Mobil Oil Corp., 545 F. 2d 422, 434-435 (CA5 1977). No increase was allowed for price inflation, on the theory that such predictions were unreliably speculative. See Sleeman, supra, at 308; Penrod, supra, at 240-241. In discounting the estimated lost stream of future income to present value, however, they applied the market interest rate. See Blue v. Western R. of Alabama, 469 F. 2d 487, 496-497 (CA5 1972).

The effect of these holdings was to deny the plaintiff the benefit of the impact of inflation on his future earnings, while giving the defendant the benefit of inflation’s impact on the interest rate that is used to discount those earnings to present value. Although the plaintiff in such a situation could invest the proceeds of the litigation at an “inflated” rate of interest, the stream of income that he received provided him with only enough dollars to maintain his existing nominal income; it did not provide him with a stream comparable to what his lost wages would have been in an inflationary economy. 24 This inequity was assumed to have been minimal because of the relatively low rates of inflation.

In recent years, of course, inflation rates have not remained low. There is now a consensus among courts that *541 the prior inequity can no longer be tolerated. See, e. g., United States v. English, 521 F. 2d 63, 75 (CA9 1975) (“While the administrative convenience of ignoring inflation has some appeal when inflation rates are low, to ignore inflation when the rates are high is to ignore economic reality”). There is no consensus at all, however, regarding what form an appropriate response should take. See generally Note, Future Inflation, Prospective Damages, and the Circuit Courts, 63 Va. L. Rev. 105 (1977).

Our sister common-law nations generally continue to adhere to the position that inflation is too speculative to be considered in estimating the lost stream of future earnings; they have sought to counteract the danger of systematically un-dercompensating plaintiffs by applying a discount rate that is below the current market rate. Nevertheless, they have each chosen different rates, applying slightly different economic theories. In England, Lord Diplock has suggested that it would be appropriate to allow for future inflation “in a rough and ready way” by discounting at a rate of 4 3/4%. Cookson v. Knowles, [1979] A. C. 556, 565-573. He accepted that rate as roughly equivalent to the rates available “[i]n times of stable currency.” Id., at 571-572. See also Mallett v. McMonagle, [1970] A. C. 166. The Supreme Court of Canada has recommended discounting at a rate of 7%, a rate equal to market rates on long-term investments minus a government expert’s prediction of the long-term rate of price inflation. Andrews v. Grand & Toy Alberta Ltd., [1978] 2 S. C. R. 229, 83 D. L. R. 3d 452, 474. And in Australia, the High Court has adopted a 2% rate, on the theory that it represents a good approximation of the long-term “real interest rate.” See Pennant Hills Restaurants Pty. Ltd. v. Barrell Insurances Pty. Ltd., 55 A. L. J. R. 258 (1981); id., at 260 (Barwick, C. J.); id., at 262 (Gibbs, J.); id., at 277 (Mason, J.); id., at 280 (Wilson, J.).

In this country, some courts have taken the same “real interest rate” approach as Australia. See Feldman v. Alie- *542 gheny Airlines, Inc., 524 F. 2d, at 388 (1.5%); Doca v. Marina Mercanti Nicaraguense, S. A., 634 F. 2d 30, 39-40 (CA2 1980) (2%, unless litigants prove otherwise). They have endorsed the economic theory suggesting that market interest rates include two components — an estimate of anticipated inflation, and a desired “real” rate of return on investment— and that the latter component is essentially constant over time. 25 They have concluded that the inflationary increase in the estimated lost stream of future earnings will therefore be perfectly “offset” by all but the “real” component of the market interest rate. 26

*543 Still other courts have preferred to continue relying on market interest rates. To avoid undercompensation, they have shown at least tentative willingness to permit evidence of what future price inflation will be in estimating the lost stream of future income. Schmitt v. Jenkins Truck Lines, Inc., 170 N. W. 2d 632 (Iowa 1969); Bach v. Penn Central Transp. Co., 502 F. 2d 1117, 1122 (CA6 1974); Turcotte v. Ford Motor Co., 494 F. 2d 173, 186-187 (CA1 1974); Huddell v. Levin, 537 F. 2d 726 (CA3 1976); United States v. English, supra, at 74-76; Ott v. Frank, 202 Neb. 820, 277 N. W. 2d 251 (1979); District of Columbia v. Barriteau, 399 A. 2d 563, 566-569 (D. C. 1979). Cf. Magill v. Westinghouse Electric Corp., 464 F. 2d 294, 301 (CA3 1972) (holding open possibility of establishing a factual basis for price inflation testimony); Resner v. Northern Pacific R. Co., 161 Mont. 177, 505 P. 2d 86 (1973) (approving estimate of future wage inflation); Taenzler v. Burlington Northern, 608 F. 2d 796, 801 (CA8 1979) (allowing estimate of future wage inflation, but not of a specific rate of price inflation); Steckler v. United States, 549 F. 2d 1372 (CA10 1977) (same).

Within the past year, two Federal Courts of Appeals have decided to allow litigants a choice of methods. Sitting en banc, the Court of Appeals for the Fifth Circuit has overruled its prior decision in Johnson v. Penrod Drilling Co., 510 *544 F. 2d 234 (1975), and held it acceptable either to exclude evidence of future price inflation and discount by a “real” interest rate, or to attempt to predict the effects of future price inflation on future wages and then discount by the market interest rate. Culver v. Slater Boat Co., 688 F. 2d 280, 308-310 (1982). 27 A panel of the Court of Appeals for the Seventh Circuit has taken a substantially similar position. O’Shea v. Riverway Towing Co., 677 F. 2d 1194, 1200 (1982).

Finally, some courts have applied a number of techniques that have loosely been termed “total offset” methods. What these methods have in common is that they presume that the ideal discount rate — the after-tax market interest rate on a safe investment — is (to a legally tolerable degree of precision) completely offset by certain elements in the ideal computation of the estimated lost stream of future income. They all assume that the effects of future price inflation on wages are part of what offsets the market interest rate. The methods differ, however, in their assumptions regarding which if any other elements in the first stage of the damages calculation contribute to the offset.

Beaulieu v. Elliott, 434 P. 2d 665 (Alaska 1967), is regarded as the seminal “total offset” case. The Supreme Court of Alaska ruled that in calculating an appropriate award for an injured worker’s lost wages, no discount was to be applied. It held that the market interest rate was fully offset by two factors: price inflation and real wage inflation. *545 Id., at 671-672. Significantly, the court did not need to distinguish between the two types of sources of real wage inflation — individual and societal — in order to resolve the case before it. 28 It simply observed:

“It is a matter of common experience that as one progresses in his chosen occupation or profession he is likely to increase his earnings as the years pass by. In nearly any occupation a wage earner can reasonably expect to receive wage increases from time to time. This factor is generally not taken into account when loss of future wages is determined, because there is no definite way of determining at the time of trial what wage increases the plaintiff may expect to receive in the years to come. However, this factor may be taken into account to some extent when considered to be an offsetting factor to the result reached when future earnings are not reduced to present value.” Id., at 672.

Thus, the market interest rate was deemed to be offset by price inflation and all other sources of future wage increases.

In State v. Guinn, 555 P. 2d 530 (Alaska 1976), the Beau-lieu approach was refined slightly. In that case, the plaintiff had offered evidence of “small, automatic increases in the wage rate keyed to the employee’s length of service with the company,” 555 P. 2d, at 545, and the trial court had included those increases in the estimated lost stream of future income but had not discounted. It held that this type of “certain and predictable” individual raise was not the type of wage increase that offsets the failure to discount to present value. Thus, the market interest rate was deemed to be offset by price inflation, societal sources of wage inflation, and individual sources of wage inflation that are not “certain and predictable.” Id., at 546-547. See also Gowdy v. United States, 271 F. Supp. 733 (WD Mich. 1967) (price inflation and *546 societal sources of wage inflation), rev’d on other grounds, 412 F. 2d 525 (CA6 1969); Pierce v. New York Central R. Co., 304 F. Supp. 44 (WD Mich. 1969) (same).

Kaczkowski v. Bolubasz, 491 Pa. 561, 421 A. 2d 1027 (1980), took still a third approach. The Pennsylvania Supreme Court followed the approach of the District Court in Feldman v. Allegheny Airlines, Inc., 382 F. Supp. 1271 (Conn. 1974), and the Court of Appeals for the Fifth Circuit in Higginbotham v. Mobil Oil Corp., 545 F. 2d 422 (1977), in concluding that the plaintiff could introduce all manner of evidence bearing on likely sources — both individual and societal — of future wage growth, except for predictions of price inflation. 491 Pa., at 579-580, 421 A. 2d, at 1036-1037. However, it rejected those courts’ conclusion that the resulting estimated lost stream of future income should be discounted by a “real interest rate.” Rather, it deemed the market interest rate to be offset by future price inflation. Id., at 580-582, 421 A. 2d, at 1037-1038. See also Schnebly v. Baker, 217 N. W. 2d 708, 727 (Iowa 1974); Freeport Sulphur Co. v. S/S Hermosa, 526 F. 2d 300, 310-312 (CA5 1976) (Wisdom, J., concurring).

The litigants and the amici in this case urge us to select one of the many rules that have been proposed and establish it for all time as the exclusive method in all federal trials for calculating an award for lost earnings in an inflationary economy. We are not persuaded, however, that such an approach is warranted. Accord, Cookson v. Knowles, [1979] A. C., at 574 (Lord Salmon). For our review of the foregoing cases leads us to draw three conclusions. First, by its very nature the calculation of an award for lost earnings must be a rough approximation. Because the lost stream can never be predicted with complete confidence, any lump sum represents only a “rough and ready” effort to put the plaintiff in the position he would have been in had he not been injured. Second, sustained price inflation can make the award substantially less precise. Inflation’s current magnitude and *547 unpredictability create a substantial risk that the damages award will prove to have little relation to the lost wages it purports to replace. Third, the question of lost earnings can arise in many different contexts. In some sectors of the economy, it is far easier to assemble evidence of an individual’s most likely career path than in others.

These conclusions all counsel hesitation. Having surveyed the multitude of options available, we will do no more than is necessary to resolve the case before us. We limit our attention to suits under § 5(b) of the Act, noting that Congress has provided generally for an award of damages but has not given specific guidance regarding how they are to be calculated. Within that narrow context, we sh