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State law · ID

Idaho diminished value claims

Idaho has no diminished-value statute. The one Idaho appellate decision found, from the Court of Appeals in 1987, let a commercial truck owner recover repair costs plus the loss in value after repair from the at-fault driver. No Idaho case was found on claims against your own insurer, so that depends on your policy wording. The deadline to sue for property damage is three years.

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  • Claim against the at-fault driver

    Allowed by case law

  • Claim against your own insurer

    Unsettled

  • Time limit to sue for property damage

    3 years

Reviewed by Monica Fisher, Owner, Licensed Auto Appraiser and Court Expert Witness — appraisal perspective, not legal advice

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Idaho law

What Idaho law says about diminished value

Third-party claim

Against the at-fault driver’s insurer

Allowed by case law

In Spreader Specialists v. Monroc, the Idaho Court of Appeals held that an owner who reasonably repairs a damaged commercial vehicle may recover the repair cost plus the vehicle's loss in value as repaired. The case involved a business vehicle and an intermediate appellate court. No Idaho Supreme Court decision on post-repair diminished value for a personal car was found, so how it applies to ordinary passenger vehicles is not certain.

Authority: Spreader Specialists, Inc. v. Monroc, Inc., 114 Idaho 15, 752 P.2d 617 (Ct. App. 1987); Idaho Code § 5-218(3)

First-party claim

Against your own insurer

Unsettled

No Idaho appellate decision or statute was found on whether an auto policy's collision or comprehensive coverage pays for diminished value. The answer is likely to turn on the policy's limit-of-liability and repair wording. Read your policy or ask the insurer to point to the language it relies on.

Case law

Key Idaho court decisions

Spreader Specialists, Inc. v. Monroc, Inc.

Idaho Court of Appeals · 1987

114 Idaho 15, 752 P.2d 617 (Ct. App. 1987)

Where a plaintiff reasonably repairs a damaged commercial vehicle to mitigate business losses, the plaintiff may recover the actual cost of repairs plus the diminution in value of the vehicle as repaired, even if that sum exceeds the before-and-after (unrepaired) value difference.

Status: treatment unclear: Decided 3 Dec 1987 (reported 1988). A secondary source (Matthiesen, Wickert & Lehrer) says it was overruled on other grounds by Walton, Inc. v. Jensen (Idaho Ct. App. 1999). That was not verified. Commercial-vehicle facts.

Read the decision

Statutes and rules

  • Idaho Code § 5-218(3): Statutory liabilities, trespass, trover, replevin, and fraud: three-year limit

    An action for taking, detaining or injuring any goods or chattels (personal property) must be brought within three years.

  • Idaho Code § 5-216: Action on written contract: five-year limit

    An action on a contract founded on an instrument in writing must be brought within five years. This may apply to a claim against your own insurer, subject to any suit-limitation clause in the policy.

  • Idaho Code § 49-117(20): Definition of proof of financial responsibility

    Sets the liability amounts at $25,000 per person and $50,000 per accident for bodily injury, and $15,000 for property damage.

Deadlines and minimum coverage

Time limit for a property-damage lawsuit
3 years (Idaho Code § 5-218(3)). Covers injury to personal property (the vehicle). Personal-injury claims have a different period. A claim against your own insurer is a contract claim (Idaho Code § 5-216, five years for written contracts), but many policies set a shorter time to sue.
Minimum liability insurance
$25,000 per person / $50,000 per accident bodily injury; $15,000 property damage. The at-fault driver’s property-damage limit can cap what their insurer pays.
If your claim stalls
You can file a complaint with the Idaho Department of Insurance.
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Appraisals for Idaho vehicles

We serve Idaho 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.

  1. 1

    Free claim review

    Tell us about the vehicle and the Idaho claim.
  2. 2

    Send photos and repair records

    Final invoice, photos, and the insurer’s claim details.
  3. 3

    Receive your appraisal

    Reviewed by Monica Fisher, with a custom demand letter.
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Have a Idaho diminished value claim?

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.