Mabry v. State Farm – Georgia Diminished Value Rights
Read the full Georgia Supreme Court opinion:
State Farm Mutual Automobile Insurance Company v. Mabry (2001)
The Georgia Supreme Court case Mabry v. State Farm confirmed that when a vehicle is damaged in an accident, insurance companies in Georgia must evaluate and pay for diminished value when it exists – not just repair physical damage.
This ruling protects drivers from losing money simply because their vehicle now has an accident history.
Why This Case Matters
State Farm argued they only needed to restore the car to pre-loss condition, but the court ruled that the true measure of loss is value – the difference between the vehicle’s value before the loss and after repairs.
In simpler terms:
- Good repairs do not erase lost market value
- Insurers must make you whole financially
- Diminished value is a covered loss
Key Findings in Mabry v. State Farm
Diminished value exists even after proper repairs
There is a potential for lost value in every accident, because the market prefers an undamaged vehicle.
Insurers must assess DV automatically
Policyholders do not have to file a separate diminished value claim.
Insurance companies must evaluate all elements of loss when a physical damage claim is made.
The insurer must pay the full difference in value
The obligation is to pay for what is actually lost — value, not just appearance or function.
The trial court ordered State Farm to comply
The injunction required State Farm to:
- Evaluate DV on every qualifying claim
- Use an appropriate methodology
- Maintain data needed to determine DV
How This Helps Georgia Drivers
Because of Mabry, insurance companies in Georgia cannot:
- Ignore DV
- Claim “repairs = no loss”
- Require you to request DV separately
So if you’ve been in an accident, you may be owed more money.
Wreck Check Atlanta Can Help
We help you recover what the law says you deserve by providing:
- Diminished Value Assessments
- Post-Repair Inspections
- Support during the claims process
For information on other insurance companies, please contact us for further details.
