Young v. Georgia Agricultural Exposition Authority, 318 Ga. App. 244

Tony Young suffered injuries from two bulls at a Perry beef exposition; the trial court granted summary judgment to GAEA on Tony’s economic loss claim; this Court previously reviewed related claims against Shelby and the agency; Tony presented evidence of income from cattle embryo services and related farming activity; tax returns from 1996–1997 showed embryo income, with later years showing losses, affecting earnings; the issue is whether the evidence raises a jury question on lost earnings despite fluctuations in income and tax reporting.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is there a jury issue on Tony’s economic loss?	Tony presented past earnings and potential future earnings evidence.	GAEA argued the evidence was speculative and lacked ascertainable basis.	Yes, jury issue exists.
Can lost earnings be proven with contested tax returns?	Past earnings and embryo income suffice to show earnings capacity.	Tax returns are too uncertain to prove lost earnings.	Judgment reversed; jury to determine damages.

Dossie v. Sherwood, 308 Ga. App. 185 (Ga. Ct. App. 2011) (loss of earnings proof when causation shown)
Crosby v. Spencer, 207 Ga. App. 487 (Ga. Ct. App. 1993) (uncertainty of damages does not bar recovery when causation shown)
Southwestern R. Co. v. Vellines, 14 Ga. App. 674 (Ga. Ct. App. 1914) (imputes earning capacity evidence when precise profits unavailable)
Gipson v. Phillips, 232 Ga. App. 235 (Ga. Ct. App. 1998) (evidence of potential earnings can support lost profits)
Quiktrip Corp. v. Childs, 220 Ga. App. 463 (Ga. Ct. App. 1996) (tax returns and present earnings can establish lost wages)
Johnson County School Dist. v. Greater Savannah Lawn Care, 278 Ga. App. 110 (Ga. Ct. App. 2006) (lost profits generally require definite ascertainment)
Kingston Pencil Corp. v. Jordan, 115 Ga. App. 333 (Ga. Ct. App. 1967) (lost profits must be capable of definite ascertainment)