UNDOCUMENTED ALIEN MAY RECOVER FUTURE EARNINGS IN ILLINOIS

Under Illinois law, as predicted by the district court, the plaintiff's status as an undocumented alien precluded the recovery of damages based on loss of future United States earnings, to which he would not lawfully be entitled because it would be based on compensation for future impermissible work, but did not preclude recovery of damages for lost future earnings or earning capacity based on what he could legitimately earn in his country of lawful residence. This approach fairly balanced the federal government's immigration policies as expressed in the Immigration Reform and Control Act (IRCA) to discourage the employment of unauthorized aliens.