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See also Work capital. A person's ability to earn money, based on a person's talent, skills, training, and experience. Earning capacity is determined by what a plaintiff 'could have earned even if he or she never worked to that capacity in the past.' 2 M. Minzer, J. Nates, C. Kimball, D. Axelrod & R. Goldstein, Damages in Tort Actions § 10.22[3][a] (citations omitted). As a California appellate court has observed, 'impairment of the capacity or power to work is an injury separate from the actual loss of earnings.' Hilliard v. A.H. Robins Co., 196 Cal.Rptr. 117, 143, 148 Cal.App. 3d 374 (Cal.App.2d Dist. ...