(concurring). I agree with the majority that the doctrine of mitigation requires the victim of wrongdoing to make reasonable efforts to mitigate damages or forfeit the right to back pay. Further, and pursuant to the doctrine of mitigation, where the victim of wrongdoing refuses an offer of “like employment,” e.g., employment that is substantially equivalent to the employment lost by wrongdoing, the victim also forfeits the right to continuing back pay and front pay. The defendant bears the burden of proving that the victim’s efforts to mitigate damages was unreasonable.1 Because I agree with the majority that the trial court’s award of back pay after August *2791990 was not clearly erroneous, I concur that the award should be reinstated.
Further, I concur with the majority’s result in section m(A). The plaintiff’s receipt of disability from September 1989 through February 1990 does not preclude a concurrent award of back pay, although the trial court correctly reduced the back pay award by the amount of disability payments.
I also concur that remand is necessary to determine whether the plaintiff’s rejection of the September and October 1992 job offers was reasonable. If the defendant demonstrates that plaintiff’s rejection was unreasonable, plaintiff is entitled to neither back pay nor front pay after October 1992. However, it remains unclear whether the trial court correctly applied the doctrine of mitigation to the front pay award.
This Court has yet to define the limits of front pay awards, and the Legislature has offered the courts no direction, despite the potential effect of such awards. Even lacking specific guidance, the facts of this case may support a modified award of front pay after plaintiff accepted a substantially similar position in February 1993.
Plaintiff in this case was twenty-two years old when he was discriminatorily discharged. He had been working for Clawson Tank for only nine months. The front pay award of $75,814 assumes plaintiff would have continued working for Clawson Tank until he retired at the age of sixty-two. The award was calculated using a growth rate of 5.26 percent a year of the present value of the difference between his future earnings at defendant Clawson Tank and Cranbrook Schools.
*280Front pay awards are speculative by nature. The Sixth Circuit has expressed concern regarding the uncertainty and potential effect of front pay awards cautioning that “an award of front pay must be governed by the sound discretion of the trial court and may not be appropriate in all cases.” Davis v Combustion Engineering, Inc, 742 F2d 916, 923 (CA 6, 1984). Davis, for example, stated:
[T]he award of front pay to a discriminatorily discharged 41 year old employee until such time as he qualifies for a pension might be unwarranted. On the other hand, the failure to make such an award for an employee age 63, likewise discriminatorily discharged, might be an abuse of discretion. [Id.]
Michigan courts also have recognized the uncertainty of front pay awards. In Riethmiller v Blue Cross & Blue Shield of Michigan, 151 Mich App 188, 201; 390 NW2d 227 (1986), the Court of Appeals wisely warned that front pay represents “the possibility of substantial monetary liability for some employers.” Riethmiller also enumerated relevant considerations in the determination whether to award front pay including: “(1) whether reinstatement would be a feasible remedy, (2) the employee’s prospects for other employment, and (3) the number of years remaining before the employee would be faced with mandatory retirement.” Id., pp 200-201. Implicit in the second consideration regarding a plaintiff’s prospects for other employment is the relevance to the award of front pay of a plaintiff’s actually obtaining other employment.
Beyond those considerations enumerated in Riethmiller, supra, the Sixth Circuit considers the following factors relevant to the award of front pay:
*281(1) the employee’s future in the position from which she was terminated; (2) her work and life expectancy; (3) her obligation to mitigate her damages; (4) the availability of comparable employment opportunities and the time reasonably required to find substitute employment; (5) the discount tables to determine the present value of future damages; and (6) “other factors that are pertinent in prospective damage awards.” [Suggs v ServiceMaster Ed Food Management, 72 F3d 1228, 1234 (CA 6, 1996).]
The federal courts thus recognize plaintiffs are obligated to mitigate their future damages as well as back pay damages. See Shore v Federal Express Corp, 42 F3d 373, 378 (CA 6, 1994).
There is an obligation to mitigate future damages. In this case, the record does not adequately reflect whether the trial court properly considered the mitigation principles with respect to future damages. It remains to be determined what constitutes future damages. As a result, I would remand not only to determine whether the plaintiff was reasonable in rejecting the defendant’s September and October job offers but also to reexamine the issue of front pay in light of the principles set forth in this opinion.
Boyle, J., concurred with Weaver, J. Taylor, J., took no part in the decision of this case.Where an offer of reinstatement is unconditional, the burden shifts to the victim to demonstrate that rejection of the offer was reasonable. Raskeed v Chrysler Corp, 445 Mich 109, 132; 517 NW2d 19 (19943; SJI2d 105.41.