· 23 decisions · last updated October 20, 2026 · statutes, rules and guidance are in the research library
MINNESOTA · SEPTEMBER 4, 2026Jamestown Villas Homeowners Association v. State Farm Fire & Casualty Co.
U.S. Court of Appeals, Eighth Circuit · No. 25-3154
The Eighth Circuit affirmed confirmation of an appraisal award after concluding the award was sufficiently clear under the Minnesota-law standards applied in the case.
Limits: A federal appellate application of Minnesota law. Do not extrapolate it to other states without separate research.
Subjects: Award
Related Minnesota authorities: Statutes Minn. Stat. §65A.01, subd. 3 (standard fire policy)
Read the decision · Minnesota appraisal law · Checked October 20, 2026
LOUISIANA · AUGUST 31, 2026Alina LLC v. State Farm Fire & Casualty Co.
U.S. District Court, Western District of Louisiana · No. 5:26-cv-00692, Doc. 29
The district court reversed a magistrate judge's order compelling appraisal after finding error in applying a reasonable-time standard to the undisputed facts.
Limits: District-court order specific to its record; not controlling law elsewhere.
Subjects: Deadlines
Read the decision · Louisiana appraisal law · Checked October 20, 2026
OHIO · JULY 23, 2026One Church v. Brotherhood Mutual Insurance Co.
Supreme Court of Ohio · 2026-Ohio-2764
The court affirmed dismissal of a complaint challenging a binding appraisal award where the pleading did not sufficiently identify a material mistake supporting relief.
Limits: Fact- and jurisdiction-specific. Read the opinion and the policy terms before treating it as a general rule.
Subjects: Award
Read the decision · Ohio appraisal law · Checked October 20, 2026
FLORIDA · MAY 21, 2026Baytree, Condominium, Section Eight, Inc. v. Clear Blue Specialty Insurance Co.
U.S. Court of Appeals, Eleventh Circuit · No. 24-10889
The opinion addresses a property insurance dispute involving appraisal demands, disputed damage scope, and the policy's notice and coverage provisions.
Limits: Read the complete opinion for its holding and procedural disposition; this entry does not state a broader rule.
Subjects: Coverage
Read the decision · Florida appraisal law · Checked October 20, 2026
TEXAS · MAY 8, 2026In re ACE American Insurance Co.
Supreme Court of Texas · Tex. May 8, 2026
The Supreme Court of Texas reaffirmed State Farm Lloyds v. Johnson and the broad contractual right to appraisal where the parties also dispute coverage, causation or bad faith.
Limits: Mandamus proceeding on specific policy language. Read the opinion for the exact holding before relying on it.
Subjects: Causation, Coverage
Related Texas authorities: Statutes Tex. Ins. Code ch. 1813 (Appraisal of Disputed Losses), added by SB 458 (2025)
Read the decision · Texas appraisal law · Checked October 20, 2026
ILLINOIS · MAY 12, 2025Xiang Zhao v. State Farm Fire & Casualty Co.
Illinois Appellate Court, Second District · 2025 IL App (2d) 240723
Affirmed an order compelling appraisal of a homeowners hail claim. Whether the storm damaged the windows was a question of loss, not coverage; questions of law and coverage are for the court, but some questions of causation are necessarily included in appraisal. The insurer's late-notice defense did not prevent appraisal.
Limits: One appellate district; property policy language specific to the case. AUA has not checked later history.
Subjects: Causation, Coverage
Read the decision · Illinois appraisal law · Checked October 20, 2026
WISCONSIN · MAY 9, 2024Badgerland Restoration & Remodeling, Inc. v. Federated Mutual Insurance Co.
Court of Appeals of Wisconsin · 2024 WI App 36
Reversed dismissal of a complaint alleging that the insurer breached the policy by refusing to participate in appraisal after the insured invoked the appraisal clause.
Limits: A ruling on a motion to dismiss; it does not decide the merits.
Subjects: Award
Read the decision · Wisconsin appraisal law · Checked October 20, 2026
COLORADO · JUNE 24, 2019Owners Insurance Co. v. Dakota Station II Condominium Ass'n
Supreme Court of Colorado · 2019 CO 65
A policy requirement that each party select an "impartial" appraiser means appraisers must be unbiased, disinterested and unswayed by personal interest, and may not advocate for either party. The contingent-cap fee agreement in the case did not make the appraiser partial as a matter of law.
Limits: Construes the policy's "impartial" wording; the fee holding rests on the facts found (neither party believed the cap applied). The case returned to the Court of Appeals on remand (2021 COA 114), which AUA has not reviewed.
Subjects: Impartiality, Contingency fees
Read the decision · Colorado appraisal law · Checked October 20, 2026
MISSOURI · DECEMBER 16, 2014American Family Mutual Insurance Co. v. Dixon
Missouri Court of Appeals, Eastern District · 450 S.W.3d 831
Where the parties disputed whether concrete damage was caused by hail or by wear and tear, the dispute was over coverage, not the amount of a covered loss, so the appraisal provision did not apply and the homeowners could litigate it in court.
Limits: One appellate district, decided on its record. AUA has not checked later Missouri decisions.
Subjects: Coverage, Causation
Related Missouri authorities: Statutes RSMo §435.350 (Validity of arbitration agreement, exceptions)
Read the decision · Missouri appraisal law · Checked October 20, 2026
GEORGIA · MARCH 26, 2014Lam v. Allstate Indemnity Co.
Court of Appeals of Georgia · 327 Ga. App. 151
Where the insurer conceded wind damage to four shingles but the parties disagreed on how much of the roof the wind damaged, the disagreement was over coverage and not a proper basis for appraisal.
Limits: Decided 4-3 with a dissent. AUA has not checked later Georgia treatment.
Subjects: Coverage, Causation
Read the decision · Georgia appraisal law · Checked October 20, 2026
MINNESOTA · JUNE 13, 2012Quade v. Secura Insurance
Supreme Court of Minnesota · 814 N.W.2d 703
The court held that the "amount of loss" an appraiser determines can include deciding the cause of the loss.
Limits: Causation remains reviewable by the courts, and coverage questions remain for the courts.
Subjects: Causation
Read the decision · Minnesota appraisal law · Checked October 20, 2026
INDIANA · FEBRUARY 10, 2012Westfield National Insurance Co. v. Nakoa
Court of Appeals of Indiana · No. 64A03-1108-PL-345 (reported at 963 N.E.2d 1126)
An insurer that let an appraisal value the loss at replacement cost without raising its actual-cash-value position waived its replacement-cost conditions. An award item granted "if Court finds coverage" left that decision to the court.
Limits: Waiver holding turns on the insurer's conduct in the case. AUA has not checked later Indiana decisions.
Subjects: Award, Coverage
Read the decision · Indiana appraisal law · Checked October 20, 2026
WISCONSIN · JULY 10, 2009Farmers Automobile Insurance Ass'n v. Union Pacific Railway Co.
Supreme Court of Wisconsin · 2009 WI 73
Appraisals are presumptively valid and may be set aside only for fraud, bad faith, a material mistake, or a lack of understanding or completion of the contractually assigned task. Discovery into the appraisal requires prima facie evidence of such a claim.
Limits: Decided with a dissent. AUA has not checked later Wisconsin treatment.
Subjects: Award
Read the decision · Wisconsin appraisal law · Checked October 20, 2026
TEXAS · JULY 3, 2009State Farm Lloyds v. Johnson
Supreme Court of Texas · 290 S.W.3d 886
Appraisers may decide causation to the extent needed to set the amount of loss; "any appraisal necessarily includes some causation element." Liability questions remain for the courts.
Limits: Applies to the policy language before the court; later Texas decisions refine when appraisal is compelled.
Subjects: Causation, Coverage
Related Texas authorities: Statutes Tex. Ins. Code ch. 1813 (Appraisal of Disputed Losses), added by SB 458 (2025)
Read the decision · Texas appraisal law · Checked October 20, 2026
GEORGIA · OCTOBER 30, 2006McGowan v. Progressive Preferred Insurance Co.
Supreme Court of Georgia · 281 Ga. 169
An appraisal clause can only resolve a disputed issue of value, not broader issues of liability; using it that way would make it an arbitration clause, which is impermissible in insurance contracts. Appraisal did not moot the insured's fraud, contract and RICO claims.
Limits: An automobile total-loss case. Georgia's Court of Appeals applied the rule to a homeowners policy in Lam.
Subjects: Coverage
Read the decision · Georgia appraisal law · Checked October 20, 2026
CALIFORNIA · JUNE 1, 2006Kacha v. Allstate Insurance Co.
California Court of Appeal, Fourth District · 140 Cal.App.4th 1023
An appraisal panel exceeded its powers by making coverage determinations; the award was ordered vacated.
Limits: California-specific; the panel's powers can be broadened only by the parties' agreement.
Subjects: Coverage, Causation, Award
Read the decision · California appraisal law · Checked October 20, 2026
FLORIDA · SEPTEMBER 26, 2002Johnson v. Nationwide Mutual Insurance Co.
Supreme Court of Florida · 828 So. 2d 1021
Causation is a coverage question for the court when the insurer wholly denies a covered loss, and an amount-of-loss question for the appraisal panel when the insurer admits a covered loss and disputes its amount.
Limits: AUA has not checked later Florida decisions applying the rule.
Subjects: Causation, Coverage
Read the decision · Florida appraisal law · Checked October 20, 2026
KANSAS · MAY 30, 1997Friday v. Trinity Universal of Kansas
Supreme Court of Kansas · 262 Kan. 347
Held that the policy's appraisal provision was a form of arbitration clause prohibited in insurance contracts by K.S.A. 5-401(c)(1).
Limits: K.S.A. 5-401 was repealed in 2018. AUA has not reviewed how Kansas courts treat appraisal clauses under the current act.
Subjects: Award
Related Kansas authorities: Statutes K.S.A. 5-401 (repealed 2018); Statutes K.S.A. 5-428 (Validity of agreement to arbitrate); Statutes Kansas HB 2351 (2025-2026), appraisal and arbitration in insurance contracts (died)
Read the decision · Kansas appraisal law · Checked October 20, 2026
OKLAHOMA · JUNE 2, 1992Massey v. Farmers Insurance Group
Supreme Court of Oklahoma · 837 P.2d 880 (corrected June 22, 1992)
Answering a certified question, the court held that the statutory appraisal clause in 36 O.S. §4803(G) makes an award binding on the party that invoked appraisal but not on the party compelled to participate.
Limits: Concerns the statutory standard fire policy clause. A separate opinion by Justice Opala would have answered the question more narrowly. AUA has not checked later Oklahoma decisions.
Subjects: Award
Related Oklahoma authorities: Statutes 36 O.S. §4803 (Oklahoma standard fire policy)
Read the decision · Oklahoma appraisal law · Checked October 20, 2026
NEBRASKA · APRIL 21, 1989Rawlings v. Amco Insurance Co.
Supreme Court of Nebraska · 231 Neb. 874
A homeowners policy's appraisal clause binding the parties to a nonjudicial determination of the amount of a future loss was against public policy and unenforceable; summary judgment for the insurer was reversed.
Limits: The Nebraska Department of Insurance still cites the decision in its 2022 guidance IGD-C11. AUA has not checked later Nebraska decisions.
Subjects: Award
Related Nebraska authorities: Department guidance Nebraska Department of Insurance Guidance Document IGD-C11 (Oct. 20, 2022)
Read the decision · Nebraska appraisal law · Checked October 20, 2026
WASHINGTON · JANUARY 7, 1988Bainter v. United Pacific Insurance Co.
Court of Appeals of Washington, Division III · 50 Wash. App. 242
Affirmed confirmation of an appraisal award. An invoked award is generally conclusive on the amount of loss, but allegations of bias, prejudice or lack of disinterestedness by an appraiser or umpire can raise fact questions for a jury.
Limits: Older intermediate appellate decision. AUA has not checked later Washington treatment.
Subjects: Award
Read the decision · Washington appraisal law · Checked October 20, 2026
SOUTH CAROLINA · MAY 2, 1966Hendricks v. American Fire & Casualty Co.
Supreme Court of South Carolina · 247 S.C. 479
Where the insurer admitted liability and only the amount was disputed, appraisal was proper. A mistake of judgment does not vitiate an award; an otherwise valid award stands unless fraud or lack of impartiality is shown.
Limits: A 1966 decision on a tractor loss. AUA has not checked later South Carolina treatment.
Subjects: Award
Read the decision · South Carolina appraisal law · Checked October 20, 2026
SOUTH CAROLINA · FEBRUARY 7, 1934L.D. Jennings Co. v. North River Insurance Co.
Supreme Court of South Carolina · 171 S.C. 548
Allegations that the insured's appraiser and the umpire adopted the insured's figures without investigation or submission of differences stated a defense of partiality and bias to an action on the award.
Limits: A ruling on the pleadings; the case returned to the court after trial in 1935 (175 S.C. 407), which AUA has not reviewed.
Subjects: Impartiality
Read the decision · South Carolina appraisal law · Checked October 20, 2026
Research, not legal advice. Each entry summarizes the linked statute, regulation, guidance or court decision as checked on the date shown. Laws change, policy wording controls, and courts in the same state can disagree. Read the source and consult a licensed attorney before relying on any entry. Coverage is not yet exhaustive: states marked "Not yet reviewed" have not been researched, not "no rule".