On April 20, 2026, as jury selection began in a Broward County courtroom, Tesla quietly settled the wrongful death lawsuit brought by the family of Edgar Monserratt Martinez — a teenager whose fatal crash was allegedly caused when a Tesla technician disabled an owner-requested 85 mph speed limiter without parental consent. The settlement amount was not disclosed, but the timing was deliberate: the case had exposed a painful gap in how the public understands wrongful death damages. Edgar was young. He had no salary, no career history, no dependents. So how do forensic economists build a multi-million-dollar damages claim around someone with zero wage loss? The answer, increasingly, runs through a category called lost household services wrongful death — and understanding how it is calculated can reshape what families and attorneys expect from any wrongful death case.
Why the Martinez Settlement Reignited the Household Services Debate
The Martinez case did not exist in a vacuum. A related Riley family trial in 2022 produced a jury verdict finding Tesla only 1% negligent on total damages of $10.5 million — making Tesla’s actual share approximately $105,000, according to NHTSA-monitored litigation records on vehicle safety accountability. Since a Miami jury returned a landmark $243 million Autopilot verdict, Tesla has settled at least four additional wrongful death lawsuits with terms kept confidential. Each of those cases forced the same actuarial reckoning: when the decedent is a minor, a retiree, or a non-working caregiver, the household services line item frequently becomes the largest single component of provable economic damages. The Tesla-Martinez settlement renewed urgent questions among families and attorneys about how a lost household services wrongful death calculation actually works — and what a properly designed calculator should do with this data.
If your case involves a fatal car accident, a car accident settlement calculator can help you understand the full range of economic damages before consulting a forensic economist.
What Counts as Lost Household Services in a Wrongful Death Claim
Courts and forensic economists recognize household services as the unpaid labor a decedent performed — and would have continued performing — for the benefit of the household. These tasks carry measurable market value even though no paycheck was ever written. According to forensic accounting guidance from the National Association of Certified Valuators and Analysts (NACVA), standard lost household services wrongful death categories include:
- Childcare and supervision — including transportation, homework assistance, and emotional support
- Meal preparation and cleanup
- Housecleaning and laundry
- Lawn care, landscaping, and exterior maintenance
- Home repair and general maintenance
- Financial management — bill payment, tax preparation, budgeting oversight
- Shopping and errands
- Care for elderly or disabled household members
Critically, even a full-time employed decedent contributes measurable household services beyond their paycheck. A surgeon who mows her own lawn, manages the family’s investment accounts, and drives children to school is providing services that a surviving spouse would need to purchase from the market after her death. For non-working spouses, retirees, and caregivers, these contributions may represent the entirety of their quantifiable economic value to the household — making lost household services wrongful death damages not a supplemental line item but the foundation of the economic damages case.
The Three Accepted Valuation Methods Forensic Economists Use
Method 1: The Input Method
The input method multiplies the number of hours spent on each task category by an hourly wage rate drawn from labor market data. Forensic economists typically source wage rates from the Bureau of Labor Statistics Occupational Employment and Wage Statistics program, using the specific occupation closest to each domestic task — for example, the wage for a “childcare worker” to value childcare hours, or the wage for a “first-line supervisor of housekeeping workers” to value cleaning labor. The hours themselves are drawn from time-use research, most commonly the American Time Use Survey (ATUS). The input method is the most granular and is preferred when detailed time-use testimony or diary evidence is available.
Method 2: The Output Method
Rather than pricing the labor hours, the output method prices the finished product or service. What would it cost to have a professional caterer prepare the equivalent of 365 home-cooked dinners annually? What does a licensed plumber charge for the repairs the decedent handled personally? The output method often produces higher valuations than the input method because it captures overhead, profit margins, and the market premium attached to professional services. Courts in most jurisdictions accept either method, though some prefer the input method as more conservative and auditable.
Method 3: The Replacement Cost / Actual Cost Method
The replacement cost method asks a single question: what would it actually cost the surviving household to replace every service the decedent provided? This is the most practical method for juries to understand and is the approach most closely tied to real-world market transactions. According to NACVA guidance on lost household services wrongful death quantification, the replacement cost method is especially persuasive when the surviving spouse has already begun incurring these costs — home cleaning invoices, childcare receipts, and landscaping contracts become direct evidence of what the jury is being asked to compensate.
The Dollar Value of a Day and the American Time Use Survey
The analytical backbone of most lost household services wrongful death claims is a publication called The Dollar Value of a Day, updated annually by Expectancy Data. This resource translates raw data from the American Time Use Survey — conducted continuously by the Bureau of Labor Statistics — into ready-to-use replacement cost tables segmented by age, sex, employment status, and the presence of children in the household. A forensic economist applying these tables to a case can quickly establish that a 42-year-old employed mother with two school-age children contributes a statistically documented number of household service hours per day, valued at a specific dollar amount per day, projected forward over her remaining work-life or life expectancy.
For minor decedents like Edgar Martinez, the calculation is inverted: rather than projecting services already being performed, economists project the household services the decedent would have provided upon reaching adulthood — typically anchored to statistical projections of educational attainment based on race, sex, family income, and geography. This is why a teenager with no earnings history can still anchor a substantial economic damages claim. The household services component begins accruing from the age at which courts recognize a minor’s domestic contributions and extends through projected life expectancy, discounted to present value. When combined with funeral and burial costs — which typically run between $10,000 and $25,000 and are recoverable in every U.S. state — even cases involving young decedents with zero wage loss carry measurable economic damages.
State-Law Variations That Affect Every Household Services Calculation
No single federal standard governs lost household services wrongful death claims. Each state’s wrongful death statute defines the permissible categories of damages, the eligible plaintiffs, and whether household services are expressly compensable. Several critical variations apply in 2026:
- Georgia represents the restrictive extreme: under Georgia’s wrongful death statute, recoverable damages are limited to the “full value of the life” of the decedent measured primarily by lost earnings capacity — household services are not independently recoverable as a separate damages category, making the choice of economic expert and methodology especially consequential.
- Maryland caps non-economic damages at $875,000 for 2026 but places no cap on economic damages, including lost household services — meaning a well-documented household services claim can drive total recovery substantially above the non-economic ceiling.
- Most jurisdictions apply a 20–35% personal consumption deduction from lost earnings projections, reflecting the share of income the decedent would have spent on themselves rather than the household. Household services valuations typically do not carry an equivalent deduction because the services benefited others directly.
- Some states require expert testimony to establish household services damages; others permit lay testimony from surviving family members about the decedent’s domestic contributions.
Reviewing your state’s specific wrongful death statute at Cornell Law School’s Legal Information Institute is an essential first step before any damages projection is prepared. State case law — not just the statute — often determines whether household services are valued at replacement cost or at a more limited measure, and whether the projections extend through work-life expectancy or full life expectancy.
Key Wrongful Death Damages Data: 2026 Reference Table
| Damages Category | Typical Range / Benchmark | Notes |
|---|---|---|
| Average wrongful death settlement (956 cases, 2019–2024) | $973,054 | Mean; median is $294,728 (Thomson Reuters data) |
| Funeral and burial costs (recoverable in all states) | $10,000–$25,000 | Direct out-of-pocket recovery |
| Personal consumption deduction (lost earnings) | 20–35% | Applied in most jurisdictions to lost earnings only |
| Maryland non-economic damages cap (2026) | $875,000 | No cap on economic damages including household services |
| Tesla 2022 Riley verdict (Tesla’s 1% share) | ~$105,000 of $10.5M total | Illustrates how apportionment affects net recovery |
| Household services — annual replacement value (employed mother, two children) | $20,000–$50,000+/year | Per Dollar Value of a Day ATUS-based tables; varies by demographics |
How a Wrongful Death Calculator Should Handle Lost Household Services
A properly engineered lost household services wrongful death calculator must do more than accept a single dollar input labeled “household services.” The calculation has too many moving parts — demographic variables, state law, projection period, discount rate, and valuation method — to be collapsed into a single field. Here is what a rigorous calculator architecture should include:
- Demographic intake: Age, sex, employment status, and household composition of the decedent — these variables drive the ATUS-based time-use baselines.
- State selection: The calculator should flag states with restrictive household services rules (such as Georgia) and states with favorable economic damages structures (such as Maryland).
- Valuation method toggle: Users should be able to switch between input, output, and replacement cost methods to see how the choice affects the total.
- Projection period: Work-life expectancy versus full life expectancy produces materially different totals — the calculator should apply the correct standard for the selected jurisdiction.
- Present value discounting: Future household services must be discounted to present value using a defensible discount rate, typically derived from U.S. Treasury yield curves.
- Personal consumption deduction flag: Applied to lost earnings but generally not to household services — the calculator must handle these two categories with different deduction logic.
For general personal injury cases that may not reach the wrongful death threshold, our personal injury settlement calculator provides a broader damages framework that includes medical expenses, lost income, and pain and suffering alongside household services disruption.
The professional team behind any household services damages claim will include at minimum a forensic economist, often a vocational rehabilitation expert to establish work-life expectancy, and in cases involving minors, experts who can testify to statistical educational and earnings trajectories. The calculator’s role is to educate families and attorneys about the order of magnitude involved — providing a credible starting point that disciplined expert analysis then refines for litigation or settlement negotiation.
Frequently Asked Questions About Lost Household Services in Wrongful Death Cases
Can household services damages be claimed even if the decedent had a full-time job?
Yes. Even fully employed decedents provide measurable household services outside working hours — meal preparation, childcare, home maintenance, financial management, and more. Forensic economists use American Time Use Survey data segmented by employment status to establish baseline hours for employed individuals. The household services claim runs parallel to the lost earnings claim and is not reduced because the decedent was employed. In high-earning households, the household services component may represent a secondary damages category, but it is never zero for a decedent who maintained an active household role.
How are household services calculated for a minor decedent with no earnings history?
For minor decedents, forensic economists project the household services the individual would have provided as an adult, using ATUS demographic baselines tied to statistical educational attainment by race, sex, family income, and geography. The projection begins at the age courts recognize adult-level domestic contributions and extends through projected life expectancy, discounted to present value. This is why cases like the Martinez matter — involving a teenager with zero wage history — can still carry substantial economic damages anchored primarily to lost household services wrongful death projections rather than lost income.
Which states do not allow lost household services as a separate damages category?
Georgia is the most frequently cited example: its wrongful death statute recovers the “full value of the life” of the decedent measured principally through lost earnings capacity, without independently itemized household services recovery. Other states have intermediate positions — allowing household services evidence but requiring it to be folded into a broader “pecuniary loss” calculation rather than presented as a standalone line item. Because state law determines what is recoverable and how it must be presented, reviewing your jurisdiction’s specific wrongful death statute and controlling case law before preparing any damages analysis is essential. The Cornell Law Legal Information Institute maintains a comprehensive wrongful death wex entry as a starting point.
What is the difference between the input method and the replacement cost method for valuing household services?
The input method prices the labor hours using occupation-specific wage rates from BLS data — for example, multiplying the hours spent on childcare by the BLS wage for childcare workers. The replacement cost method prices the actual market cost to hire someone to perform each specific service, which often includes overhead and professional margins and may produce higher valuations. Courts accept both methods, though replacement cost is often more intuitive for juries because it mirrors real-world transactions. A forensic economist may present both methods and allow the trier of fact to choose, or advocate for the method that produces the more defensible and favorable valuation under the specific facts of the case.
Does a wrongful death calculator give me the final settlement value for household services damages?
No calculator — including ours — produces a final legal damages figure. A wrongful death calculator provides an informed, data-driven estimate of the economic damages range based on demographic inputs, state law parameters, and established valuation benchmarks. The actual damages in any litigated or settled case are determined by forensic economists, vocational experts, and ultimately by negotiation or jury verdict. Lost household services wrongful death calculations are particularly sensitive to individual facts: the specific services provided, the hours documented, the state’s evidentiary requirements, and the expert’s methodology. The calculator’s value is in helping families and attorneys understand the financial magnitude of what was lost before engaging the expert team that will build the formal damages analysis.
This article is provided for general informational purposes only and does not constitute legal advice; consult a licensed attorney in your jurisdiction regarding the specific facts of your wrongful death claim.
Related reading: personal injury settlement calculator
Related reading: personal injury settlement calculator
Margaret Whitfield is a Wrongful Death and Survivor Rights Advisor with extensive knowledge of personal injury law and settlement values across the United States. With years of experience analyzing wrongful death claims only (high value) cases, Margaret helps injury victims understand their legal rights and the potential value of their claims. Margaret is not an attorney and the information provided is for educational purposes only.