Under Arkansas law, an injured person can recover “[t]he reasonable expense of any necessary medical care, treatment and services received . . . and the present value of such expense reasonably certain to be required in the future.” AMI 2204. This means if an injured person has received $100 in medical treatment, then they can present $100 in medical treatment to the jury if the charges for the treatment were reasonable. However, if the injured person claims $100 in medical treatment and $1,000 in future medical treatment, then they can present the $1,000 in future medical treatment only if the future charges are “reasonably certain” to be incurred. What “reasonably certain” means has been discussed at length by Arkansas courts. Usually, testimony from a treating doctor on the seriousness of the injury and the need for future medical treatment will be enough to allow future medical expenses to be submitted to the jury.