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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.

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