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Excerpt from Millott v. Reinhard

Dependency Rates

[270] I agree with Brown that some deduction must be made to account for those household services provided by Millott which were for his sole benefit. For example, his time to clean up his own dishes after meals does not need to be replaced and should not be compensated for. However, I cannot accept Brown's contention that 25 per cent of the household services should be deducted off the top as benefiting only Millott (and later one-third and one-half). I prefer the logic in [the plaintiff's expert]'s reasoning that there is only a slight decrease in the amount of household work that must still be done, despite the absence of one person.

[271] As [the plaintiff's expert] noted, Kirker divided her report into regular cleaning, seasonal cleaning, outdoor maintenance, and maintenance and repair. Given the nature of household services provided by Millott, I estimate that ten per cent of these activities were for Millott's sole benefit, and need not be replaced. For example, his absence from the house will result in fewer dishes to wash, slightly less dirt accumulating in the house, and less wear and tear on appliances decreasing the maintenance and repair requirements. (Other activities, such as laundry, are specifically not considered, as Millott did not perform a significant amount of such tasks.) However, the work Millott did outside the house was all for the family's benefit as a whole, such as his portion of the lawn mowing and snow shovelling, other yard work, and outside cleaning.

[272] Therefore, once the annual value of Millott's household services is determined below, ten per cent must be deducted as representing the amount of his services that do not need to be replaced. I have reached this figure because virtually everything Millott did was for the family as a whole. For example, he did not have a hobby car that he spent time working on. In my view, it is inappropriate to make a significant deduction here.