British Columbia, Canada
The following excerpt is from Beaudoin v Fennell, 2019 BCSC 852 (CanLII):
Citing Spehar v. Beazley, 2004 BCCA 290, the plaintiff submits that the level of care to be provided by a cost of future care award should reflect the reasonable or normal expectations of what the injured person will require.
The plaintiff submits based on O’Connell v. Yung, 2012 BCCA 57, that claims for loss of homemaking capacity and for future cost of care are distinct. Future cost of care is for the value of certain services that must now be rendered to the plaintiff and are directly related to the expenses reasonably expected to be required. A loss of homemaking claim is a loss of the value of work that the plaintiff is prevented from doing due to her injuries.