Appraisal and Coverage Questions by State
Whether an appraisal panel may decide coverage, and how the policy's terms, limits and deductibles apply to the award.
10 states have a researched rule on coverage, drawn from court decisions and statutes, with 10 court decisions on the subject. Other states are not yet reviewed.
| State | Rule |
|---|---|
| California | Not allowed |
| Georgia | Not allowed |
| Illinois | Decided by the court (property) |
| Indiana | Left to the court |
| Iowa | Policy terms still apply |
| Louisiana | Only for accepted claims; policy terms still apply |
| Missouri | Not allowed |
| New York | Not allowed |
| Oklahoma | Amount of loss only (federal reading) |
| Texas | Amount of loss only |
California
Not allowed. In Kacha v. Allstate Insurance Co., 140 Cal.App.4th 1023 (2006), the Court of Appeal held that an appraisal panel exceeded its powers by making coverage determinations and ordered the award vacated.
- Court decision Kacha v. Allstate Insurance Co. (140 Cal.App.4th 1023, 2006)
Full California entry · verified October 20, 2026
Georgia
Not allowed. An appraisal clause "can only resolve a disputed issue of value. It cannot be invoked to resolve broader issues of liability"; using it that way would turn it into an arbitration clause, which is impermissible in insurance contracts under O.C.G.A. §9-9-2(c)(3) (McGowan v. Progressive Preferred Ins. Co., 281 Ga. 169 (2006), an automobile case). The Court of Appeals applied this rule to a homeowners policy in Lam v. Allstate Indemnity Co. (2014).
- Court decision Lam v. Allstate Indemnity Co. (327 Ga. App. 151, 2014); McGowan v. Progressive Preferred Insurance Co. (281 Ga. 169, 2006)
Full Georgia entry · verified October 20, 2026
Illinois
Decided by the court (property). In Zhao, the court said questions of law and coverage are for the court. It also held that the insurer's late-notice defense did not prevent appraisal: under the policy's terms, neither party waived its contractual rights by entering appraisal, and the effect of the delay could be decided later if the case continued.
- Court decision Xiang Zhao v. State Farm Fire & Casualty Co. (2025 IL App (2d) 240723, 2025)
Full Illinois entry · verified October 20, 2026
Indiana
Left to the court. In Westfield National Insurance Co. v. Nakoa (Ind. Ct. App. Feb. 10, 2012), the umpire's award listed $10,200 for loss of use "if Court finds coverage for this loss." The court held that the award was "not the last word on the subject" and left the decision to the trial court, which properly declined to award it.
- Court decision Westfield National Insurance Co. v. Nakoa (No. 64A03-1108-PL-345 (reported at 963 N.E.2d 1126), 2012)
Full Indiana entry · verified October 20, 2026
Iowa
Policy terms still apply. Payment of an award is subject to the policy's limits, terms, deductibles and prior payments, and the insurer must explain in writing any item specifically denied under the policy (§522F.16(2)).
Full Iowa entry · verified October 20, 2026
Louisiana
Only for accepted claims; policy terms still apply. The statutory appraisal process applies when the insurer has accepted coverage in whole or in part and the dispute is over the amount of loss on the accepted portion (La. R.S. 22:1807.12). The award sets the amount of loss subject to the policy's terms, limits, deductibles and conditions (§1807.13(D)).
Full Louisiana entry · verified October 20, 2026
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)).
- Statutes RSMo §435.350 (Validity of arbitration agreement, exceptions)
- Court decision American Family Mutual Insurance Co. v. Dixon (450 S.W.3d 831, 2014)
Full Missouri entry · verified October 20, 2026
New York
Not allowed. Appraisal determines actual cash value, replacement cost, the extent of the loss and the amount of loss; it proceeds under the policy's appraisal clause "and not as an arbitration" and may not determine whether the policy covers any part of the loss (Ins. Law §3408).
- Statutes N.Y. Insurance Law §3408
Full New York entry · verified October 20, 2026
Oklahoma
Amount of loss only (federal reading). Applying Oklahoma law, the Tenth Circuit described the appraisal process as "only conclusive as to the amount of loss" and said it "has no bearing on coverage, causation, or other elements of liability," citing Massey (In re Hayes Family Trust, No. 15-6164 (10th Cir. Jan. 4, 2017)). This is a federal court's reading of Oklahoma law.
Full Oklahoma entry · verified October 20, 2026
Texas
Amount of loss only. Under Johnson, appraisers determine the amount of damage while questions of coverage and liability are reserved for the courts. For personal auto and residential property policies since January 1, 2026, the required appraisal provision is "solely to determine the amount of loss" (Tex. Ins. Code §1813.003(b)), and an appraisal "does not affect any applicable policy terms" (§1813.004(a)).
- Statutes Tex. Ins. Code ch. 1813 (Appraisal of Disputed Losses), added by SB 458 (2025)
- 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
Court decisions on this subject in other states
- Florida: Baytree, Condominium, Section Eight, Inc. v. Clear Blue Specialty Insurance Co. (No. 24-10889, 2026): The opinion addresses a property insurance dispute involving appraisal demands, disputed damage scope, and the policy's notice and coverage provisions.
- Florida: Johnson v. Nationwide Mutual Insurance Co. (828 So. 2d 1021, 2002): 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.
Other subjects: State license · Contingency fees · Impartiality · Umpire selection · Causation · 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 coverage in California?
Not allowed. In Kacha v. Allstate Insurance Co., 140 Cal.App.4th 1023 (2006), the Court of Appeal held that an appraisal panel exceeded its powers by making coverage determinations and ordered the award vacated.
Can an appraisal panel decide coverage in Georgia?
Not allowed. An appraisal clause "can only resolve a disputed issue of value. It cannot be invoked to resolve broader issues of liability"; using it that way would turn it into an arbitration clause, which is impermissible in insurance contracts under O.C.G.A. §9-9-2(c)(3) (McGowan v. Progressive Preferred Ins. Co., 281 Ga. 169 (2006), an automobile case). The Court of Appeals applied this rule to a homeowners policy in Lam v. Allstate Indemnity Co. (2014).
Can an appraisal panel decide coverage in Illinois?
Decided by the court (property). In Zhao, the court said questions of law and coverage are for the court. It also held that the insurer's late-notice defense did not prevent appraisal: under the policy's terms, neither party waived its contractual rights by entering appraisal, and the effect of the delay could be decided later if the case continued.
Can an appraisal panel decide coverage in Indiana?
Left to the court. In Westfield National Insurance Co. v. Nakoa (Ind. Ct. App. Feb. 10, 2012), the umpire's award listed $10,200 for loss of use "if Court finds coverage for this loss." The court held that the award was "not the last word on the subject" and left the decision to the trial court, which properly declined to award it.
Can an appraisal panel decide coverage in Iowa?
Policy terms still apply. Payment of an award is subject to the policy's limits, terms, deductibles and prior payments, and the insurer must explain in writing any item specifically denied under the policy (§522F.16(2)).
Can an appraisal panel decide coverage in Louisiana?
Only for accepted claims; policy terms still apply. The statutory appraisal process applies when the insurer has accepted coverage in whole or in part and the dispute is over the amount of loss on the accepted portion (La. R.S. 22:1807.12). The award sets the amount of loss subject to the policy's terms, limits, deductibles and conditions (§1807.13(D)).
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)).
Can an appraisal panel decide coverage in New York?
Not allowed. Appraisal determines actual cash value, replacement cost, the extent of the loss and the amount of loss; it proceeds under the policy's appraisal clause "and not as an arbitration" and may not determine whether the policy covers any part of the loss (Ins. Law §3408).
Can an appraisal panel decide coverage in Oklahoma?
Amount of loss only (federal reading). Applying Oklahoma law, the Tenth Circuit described the appraisal process as "only conclusive as to the amount of loss" and said it "has no bearing on coverage, causation, or other elements of liability," citing Massey (In re Hayes Family Trust, No. 15-6164 (10th Cir. Jan. 4, 2017)). This is a federal court's reading of Oklahoma law.
Can an appraisal panel decide coverage in Texas?
Amount of loss only. Under Johnson, appraisers determine the amount of damage while questions of coverage and liability are reserved for the courts. For personal auto and residential property policies since January 1, 2026, the required appraisal provision is "solely to determine the amount of loss" (Tex. Ins. Code §1813.003(b)), and an appraisal "does not affect any applicable policy terms" (§1813.004(a)).