Loss of Earnings CapacityIn Boucher v Wal-Mart Canada Corp. (Ont CA, 2014), the court suggests that, on the right facts, a claim for loss of earning capacity is conceivable in a wrongful dismissal context:
 .... In Canada, as the trial judge said in her ruling, an award for future loss of income compensates a plaintiff for loss of earning capacity – in other words, the loss of an asset, the capacity to earn: see M.B. v. British Columbia, 2003 SCC 53 (CanLII),  2 S.C.R. 477; Lazare v. Harvey, 2008 ONCA 171 (CanLII). Typically, in personal injury actions, plaintiffs have justifiable future loss of income claims because the accident has impaired their capacity to earn income.
 A claim for future loss of income can arise in an employment context where a plaintiff has not recovered from the effects of the wrongdoer’s action and the plaintiff has thus suffered a loss of any earning capacity because of the wrongdoer’s tortious conduct: see, for example, Piresferreira.