The Appellate Division, First Department yesterday decided two cases — Sanango v. 200 E. 16th Str. Hous. Corp. and Balbuena v. IDR Realty Inc. — concerning whether an illegal alien can seek future lost wages he or she could have earned but for the injury sustained (see prior post on the issue). The Court’s decision that an illegal alien is not entitled to recover lost earnings damages based on the wages he or she might have earned illegally in the United States is faithful to the Supreme Court of United States’ holding in Hoffman Plastic v. Nat’l Labor Relations Bd.