In the case of Jones & Laughlin Steel Corp. v. Pfeifer, 1982, the U.S Supreme Court was tasked with determining a fair method for calculating damages in personal injury cases under federal maritime law. The plaintiff, Joseph Pfeifer, had been injured while working on a barge owned by Jones & Laughlin Steel Corporation and sought compensation for his lost future earnings due to disability caused by the accident. The court ruled that when assessing damages for loss of future earnings in such cases, it should be assumed that wages would have increased at an annual rate equal to inflation and any amount awarded should be discounted back to present value using an interest rate reflecting the safest available investment (risk-free). This approach aims to ensure that plaintiffs are fully compensated without being overcompensated or undercompensated due to fluctuations in wage growth rates or discount rates.

In the dissenting opinion for Jones & Laughlin Steel Corp. v. Pfeifer, Justice Powell argued that the majority's decision to remand the case back to lower courts was unnecessary and could potentially lead to inconsistent results in future cases. He believed that there was already a clear standard set by previous court decisions on how damages should be calculated in personal injury cases involving loss of future earnings, which involves discounting them to present value based on market interest rates. However, he disagreed with the majority's view that juries should also consider inflation when calculating these damages as it would introduce uncertainty and speculation into their deliberations due its unpredictable nature. Furthermore, he expressed concern about requiring juries to make complex economic calculations without proper guidance from expert witnesses or instructions from judges.