In Auto-Owners Ins. Co. v. Tompkins, 651 So. 2d 89 (Fla. 1995), the supreme court rejected the mandatory rule that a jury must find that a plaintiff has suffered a permanent injury before it can award future economic damages, ruling instead that "in order to recover future economic damages, a claimant must establish only that the future economic damages are reasonably certain to occur." Id. at 90.