Can Appraisers Decide Causation? State-by-State Rules
Whether an appraisal panel may decide what caused the damage as part of the amount of loss, or whether causation is a coverage question reserved for the courts.
8 states have a researched rule on causation, drawn from court decisions and statutes, with 8 court decisions on the subject. Other states are not yet reviewed.
| State | Rule |
|---|---|
| California | Limited |
| Florida | Panel decides if coverage admitted |
| Georgia | Extent of covered damage treated as coverage |
| Illinois | Some causation within appraisal (property) |
| Iowa | Covered peril must be stated; case law not yet reviewed |
| Minnesota | Allowed |
| Missouri | Whether a peril caused the damage treated as coverage |
| Texas | Allowed (within amount of loss) |
California
Limited. Kacha follows Safeco Ins. Co. v. Sharma (1984): unless the parties agree to give the panel broader powers, an appraisal panel may not decide whether the insured event caused the claimed damage. Read the opinions before relying on this summary.
- Court decision Kacha v. Allstate Insurance Co. (140 Cal.App.4th 1023, 2006)
Full California entry · verified October 20, 2026
Florida
Panel decides if coverage admitted. Johnson v. Nationwide Mutual Insurance Co., 828 So. 2d 1021 (Fla. 2002): "causation is a coverage question for the court when an insurer wholly denies that there is a covered loss and an amount-of-loss question for the appraisal panel when an insurer admits that there is covered loss, the amount of which is disputed."
- Court decision Johnson v. Nationwide Mutual Insurance Co. (828 So. 2d 1021, 2002)
Full Florida entry · verified October 20, 2026
Georgia
Extent of covered damage treated as coverage. In Lam v. Allstate Indemnity Co., 327 Ga. App. 151 (2014), the insurer conceded wind damage to four shingles and the parties disagreed on how much of the roof the wind had damaged. The Court of Appeals (4-3) held that this disagreement was "over coverage, which is not a proper basis for an appraisal," and affirmed dismissal of the homeowner's suit to compel appraisal.
- Court decision Lam v. Allstate Indemnity Co. (327 Ga. App. 151, 2014)
Full Georgia entry · verified October 20, 2026
Illinois
Some causation within appraisal (property). Xiang Zhao v. State Farm Fire & Casualty Co., 2025 IL App (2d) 240723 (homeowners hail claim): whether the hailstorm damaged the windows "is not an issue of coverage. It is an issue of loss." The court held that "[w]hile questions of law and coverage are to be decided by the court, resolving some questions of causation will be necessarily included in the appraisal process," and affirmed an order compelling appraisal.
- Court decision Xiang Zhao v. State Farm Fire & Casualty Co. (2025 IL App (2d) 240723, 2025)
Full Illinois entry · verified October 20, 2026
Iowa
Covered peril must be stated; case law not yet reviewed. Chapter 522F requires each side to provide a scope of loss of a covered peril, and the award must state the covered peril (§522F.14). AUA has not yet reviewed Iowa case law on causation in appraisal.
Full Iowa entry · verified October 20, 2026
Minnesota
Allowed. In Quade v. Secura Insurance, 814 N.W.2d 703 (Minn. 2012), the Minnesota Supreme Court held that an appraiser's determination of the "amount of loss" may include deciding the cause of the loss. Coverage questions remain for the courts.
- Court decision Quade v. Secura Insurance (814 N.W.2d 703, 2012)
Full Minnesota entry · verified October 20, 2026
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.
- Court decision American Family Mutual Insurance Co. v. Dixon (450 S.W.3d 831, 2014)
Full Missouri entry · verified October 20, 2026
Texas
Allowed (within amount of loss). State Farm Lloyds v. Johnson, 290 S.W.3d 886 (Tex. 2009): "Any appraisal necessarily includes some causation element" because setting the amount of loss requires separating damage from the covered event from damage caused by everything else. Appraisers decide damages; courts decide liability. The court reaffirmed Johnson in In re ACE American Insurance Co. (Tex. May 8, 2026).
- Court decision In re ACE American Insurance Co. (Tex. May 8, 2026, 2026); State Farm Lloyds v. Johnson (290 S.W.3d 886, 2009)
Full Texas entry · verified October 20, 2026
Other subjects: State license · Contingency fees · Impartiality · Umpire selection · Coverage · Award · Deadlines
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".
Frequently asked questions
Can an appraisal panel decide causation in California?
Limited. Kacha follows Safeco Ins. Co. v. Sharma (1984): unless the parties agree to give the panel broader powers, an appraisal panel may not decide whether the insured event caused the claimed damage. Read the opinions before relying on this summary.
Can an appraisal panel decide causation in Florida?
Panel decides if coverage admitted. Johnson v. Nationwide Mutual Insurance Co., 828 So. 2d 1021 (Fla. 2002): "causation is a coverage question for the court when an insurer wholly denies that there is a covered loss and an amount-of-loss question for the appraisal panel when an insurer admits that there is covered loss, the amount of which is disputed."
Can an appraisal panel decide causation in Georgia?
Extent of covered damage treated as coverage. In Lam v. Allstate Indemnity Co., 327 Ga. App. 151 (2014), the insurer conceded wind damage to four shingles and the parties disagreed on how much of the roof the wind had damaged. The Court of Appeals (4-3) held that this disagreement was "over coverage, which is not a proper basis for an appraisal," and affirmed dismissal of the homeowner's suit to compel appraisal.
Can an appraisal panel decide causation in Illinois?
Some causation within appraisal (property). Xiang Zhao v. State Farm Fire & Casualty Co., 2025 IL App (2d) 240723 (homeowners hail claim): whether the hailstorm damaged the windows "is not an issue of coverage. It is an issue of loss." The court held that "[w]hile questions of law and coverage are to be decided by the court, resolving some questions of causation will be necessarily included in the appraisal process," and affirmed an order compelling appraisal.
Can an appraisal panel decide causation in Iowa?
Covered peril must be stated; case law not yet reviewed. Chapter 522F requires each side to provide a scope of loss of a covered peril, and the award must state the covered peril (§522F.14). AUA has not yet reviewed Iowa case law on causation in appraisal.
Can an appraisal panel decide causation in Minnesota?
Allowed. In Quade v. Secura Insurance, 814 N.W.2d 703 (Minn. 2012), the Minnesota Supreme Court held that an appraiser's determination of the "amount of loss" may include deciding the cause of the loss. Coverage questions remain for the courts.
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 causation in Texas?
Allowed (within amount of loss). State Farm Lloyds v. Johnson, 290 S.W.3d 886 (Tex. 2009): "Any appraisal necessarily includes some causation element" because setting the amount of loss requires separating damage from the covered event from damage caused by everything else. Appraisers decide damages; courts decide liability. The court reaffirmed Johnson in In re ACE American Insurance Co. (Tex. May 8, 2026).