Missouri Insurance Appraisal Law
Missouri courts apply appraisal only to disputes over the amount of a covered loss. Where the parties disputed whether damage was caused by hail at all, the Eastern District treated it as a coverage question for the court.
Scope: Property insurance appraisal under policy appraisal clauses. Missouri's arbitration statute excludes contracts of insurance (RSMo §435.350).
Partially reviewed Review due Verified against the linked sources on October 20, 2026 · next review January 18, 2027
| Subject | Missouri rule | Authority and related decisions |
|---|---|---|
| Causation | Whether a peril caused the damage treated as coverage. In Dixon, the insurer's appraiser concluded that scaling, pitting and pop-outs on the homeowners' concrete were caused by wear and tear, not hail. The court reversed summary judgment for the insurer, holding that the dispute was whether those claims were covered losses, not the amount of a covered loss, and could be litigated in court. | Court decision American Family Mutual Insurance Co. v. Dixon, 450 S.W.3d 831 (Mo. App. E.D. 2014) Court decision American Family Mutual Insurance Co. v. Dixon (450 S.W.3d 831, 2014) |
| Coverage | Not allowed. Whether an appraisal provision applies depends on whether the dispute is over coverage or over the amount of loss. Using appraisal to resolve coverage would be arbitration, which §435.350 does not validate for contracts of insurance (American Family Mutual Insurance Co. v. Dixon, 450 S.W.3d 831 (Mo. App. E.D. 2014)). | Court decision American Family Mutual Insurance Co. v. Dixon, 450 S.W.3d 831 (Mo. App. E.D. 2014) Statutes RSMo §435.350 (Validity of arbitration agreement, exceptions) Court decision American Family Mutual Insurance Co. v. Dixon (450 S.W.3d 831, 2014) |
Not yet reviewed for Missouri: state license, contingency fees, impartiality, umpire selection, award, deadlines.
Missouri authorities by category
Statutes and legislation
Administrative rules and codes
Regulator: Missouri Department of Commerce and Insurance
Missouri court decisions
- American Family Mutual Insurance Co. v. Dixon (450 S.W.3d 831, 2014) (Missouri Court of Appeals, Eastern District): 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. Subjects: Coverage, Causation
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".
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Frequently asked questions
Can an appraisal panel decide causation in Missouri?
Whether a peril caused the damage treated as coverage. In Dixon, the insurer's appraiser concluded that scaling, pitting and pop-outs on the homeowners' concrete were caused by wear and tear, not hail. The court reversed summary judgment for the insurer, holding that the dispute was whether those claims were covered losses, not the amount of a covered loss, and could be litigated in court.
Can an appraisal panel decide coverage in Missouri?
Not allowed. Whether an appraisal provision applies depends on whether the dispute is over coverage or over the amount of loss. Using appraisal to resolve coverage would be arbitration, which §435.350 does not validate for contracts of insurance (American Family Mutual Insurance Co. v. Dixon, 450 S.W.3d 831 (Mo. App. E.D. 2014)).