In St. Mary's Hospital, Inc. v. Phillipe, 699 So. 2d 1017 (Fla. 4th DCA 1997), the arbitrators awarded a total of $ 2,284,804 for economic damages to the Phillipe family. Of that amount, $ 1,671,424 was for loss of services and $ 613,380 was for loss of earning capacity from the date of Juslin Phillipe's death. St. Mary's argues that the award for loss of earning capacity was improper because this element of damages is not available under the Wrongful Death Act. In Franzen v. Mogler, 699 So. 2d 1026 (Fla. 4th DCA 1997), the arbitrators awarded a total of $ 905,637 for economic damages. This award included amounts for Donna and Henry Mogler's past and future medical expenses and past and future loss of services. Donna Mogler was also awarded past and future wage loss. The estate was awarded medical expenses, funeral expenses, and wage loss of the minor decedent. Franzen argues that the only elements of economic damages available under the Wrongful Death Act to the Moglers are the medical and funeral bills to the estate, which total $ 8,172. The Florida Defense Lawyers Association argues that the only elements of economic damages available to the Moglers are the survivors' loss of services and the medical and funeral expenses incurred by the estate, which total $ 24,072.