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State law · AZ
Arizona appellate courts allow a vehicle owner to recover repair cost plus any proven loss in market value from the at-fault driver, and the owner does not have to sell the car first (Oliver v. Henry, 2011). No Arizona appellate ruling on diminished value under your own policy was found, so that depends on the policy. The deadline for a property damage suit is two years.
Claim against the at-fault driver
Allowed by case law
Claim against your own insurer
Depends on your policy
Time limit to sue for property damage
2 years
Insurance regulator
Reviewed by Monica Fisher, Owner, Licensed Auto Appraiser and Court Expert Witness — appraisal perspective, not legal advice
Last reviewed
Arizona law
Third-party claim
Allowed by case law
Arizona's Court of Appeals held in 1983 that damages for a negligently damaged vehicle may include repair cost plus proven residual loss in fair market value and loss of use. In 2011 it held the owner need not sell or trade the car; the loss can be proven by expert appraisal. The owner still has to prove the amount.
Authority: Farmers Insurance Co. of Arizona v. R.B.L. Investment Co., 138 Ariz. 562, 675 P.2d 1381 (App. 1983); Oliver v. Henry, 227 Ariz. 514, 260 P.3d 314 (App. 2011)
First-party claim
Depends on your policy
No Arizona appellate decision on whether collision coverage pays diminished value was found. The Arizona cases above are tort (third-party) cases. Courts in most other states have enforced repair-or-replace wording and express DV exclusions, so the answer depends on your policy's language.
Case law
Arizona Court of Appeals · 1983
138 Ariz. 562, 675 P.2d 1381 (App. 1983)
The owner of a negligently damaged vehicle may recover repair cost plus proven residual loss in fair market value and loss of use; recovery is not limited to repair cost.
Arizona Court of Appeals, Division One · 2011
227 Ariz. 514, 260 P.3d 314 (App. 2011)
An owner can prove an actual loss of diminished value after repair without selling, trading, or otherwise disposing of the vehicle; expert appraisal evidence may prove it. Affirmed an $8,975 award for a repaired 2008 Jeep Wrangler.
A.R.S. § 12-542: Two-year limitation, including injury to property
Actions for trespass for injury done to the estate or property of another must be commenced within two years after the cause of action accrues.
A.R.S. § 28-4009(A)(2): Motor vehicle liability policy minimum limits
For policies issued or renewed on or after July 1, 2020: $25,000 per person, $50,000 per accident bodily injury, $15,000 property damage (previously 15/30/10).
Researched September 30, 2026. General information from an appraisal perspective, not legal advice.
“I finally received a check from AAA for $7077.98 for DV in my 2010 Subaru. They originally only wanted to give me $3465.00. Thank you for putting together the manual on how to fight back. It was a great help. AAA pulled a few of the tricks mentioned in the manual. I stuck to my guns and did not get in a hurry. I was trying to squeeze out $8,000.00 from them but I am happy with the $7,077.98. I am so glad I went with you guys. It was worth the fee I paid you. Jan Lougher”
Individual results vary based on the vehicle, evidence, insurer, state, coverage, and circumstances of each claim. Past results do not guarantee a similar outcome.
Autoloss in AZ
We serve Arizona from your repair order, photos and records, the same way we serve every state. A typical diminished-value appraisal is $250–$350, typically 24–48 hours after all required information is received.
Other states
The claim review is free: we look at your situation and tell you whether an appraisal is likely to help. The appraisal itself is a paid report. We help from start to finish, including a custom demand letter, and our support staff is a phone call away throughout the process.
