Insurer guide · Rulings mostly on total loss
Diminished value claims with Liberty Mutual
The one appellate diminished value decision we found involving a Liberty Mutual company comes from Montana. In Hop v. Safeco (2011) the Montana Supreme Court reversed a class action brought by third-party claimants on a procedural ground and did not decide whether the loss is owed. Most other rulings concern totaled cars, including federal appeals decisions on condition adjustments.
By the Autoloss team · Reviewed by Monica Fisher · Published
Which company, and which claim
Liberty Mutual sells insurance through several companies, and court cases name the one that issued the policy. When we checked in November 2026, Liberty Mutual’s site said Safeco Insurance was acquired by Liberty Mutual in 2008 and that the Safeco name is now retired. In Lara (below), the Ninth Circuit referred to First National Insurance Company of America and LM General Insurance Company together as “Liberty.”
The second question is whose policy you are claiming on. A Liberty Mutual policyholder claims under the policy. Someone hit by a Liberty Mutual driver is a third-party claimant, and state law decides what that driver owes. First-party vs third-party diminished value explains the difference. Autoloss is independent and is not affiliated with or endorsed by Liberty Mutual or Safeco. The names are used only to identify the insurers.
Montana: Hop v. Safeco (2011)
Hop’s 2006 Corvette, bought with 4,000 miles on it, was struck by a car driven by a Safeco policyholder 33 days later. Besides the cost of repair, he asked for “residual diminished value,” which the Montana Supreme Court described as “the difference between the value of a vehicle immediately before an accident and the value of the vehicle after post-accident repairs have been made.” When Safeco did not pay it, the trial court certified a class of third-party claimants.
The Supreme Court reversed. Under Montana’s unfair trade practices statute, a third-party claimant may not sue the insurer under that section until the underlying claim is settled or a judgment is entered on it, and Hop’s claim had not been. The court said it “has not yet addressed the question of whether insurers in Montana have an obligation to pay RDV claims at all, much less in advance,” and sent the case back with instructions to dismiss the class action without prejudice.
So Hop is a ruling about when and how a third party can sue the insurer, not about whether diminished value is recoverable from an at-fault driver. The Montana page covers that question.
Total-loss rulings involving Liberty Mutual companies
These cases are about totaled cars, not repaired ones. Several turn on the condition adjustment, a deduction a valuation applies to reflect the difference between your car and dealer-lot comparables.
| Court and year | Case | What the court decided |
| U.S. Court of Appeals, Ninth Circuit (Washington law), 2022 | Lara v. First National Ins. Co. of America | Affirmed denial of class certification over the CCC condition adjustment. Whether the adjustment broke Washington regulations was a common question, but each owner would have to show injury by comparing the car’s actual value with the payment. The court also said only the Washington insurance commissioner can prosecute violations of the regulation. |
| U.S. Court of Appeals, Eleventh Circuit (Florida law), 2023 | Signor v. Safeco Ins. Co. of Illinois | Affirmed summary judgment for Safeco. Its use of the CCC system, advertised prices and a uniform condition adjustment complied with Florida’s statute, and it did not have to pay dealer fees. One judge dissented on the condition adjustment. |
| Massachusetts Appeals Court, 2018 | Skiffington v. Liberty Mutual | A third-party claimant’s 2005 Altima was a total loss. The court held that loss of use under the standard Massachusetts policy covers costs actually incurred, and declined her claim for title, registration and inspection-sticker costs because she cited no policy language for it. |
| Colorado Court of Appeals, 2024 | Trudgian v. LM General | Colorado’s statute requires insurers to pay title and registration fees on a total loss, but the court held it creates no implied private right of action. Summary judgment for LM General affirmed. |
| U.S. Court of Appeals, Third Circuit (Pennsylvania), 2023 | Ke v. Liberty Mutual | Nonprecedential. The policy let Liberty Mutual choose between paying actual cash value and paying for repairs, and it could declare the van a total loss. |
Most of these went for the insurer on the legal question in front of the court, and several were about class actions rather than one owner’s claim. Lara in particular leaves an individual owner free to show that a particular valuation was too low. Disputing comparables and condition adjustments explains how to check one.
A regulator action
In a 2017 consent agreement with Rhode Island’s Department of Business Regulation, Liberty Mutual Insurance Group reported reviewing 2,169 total-loss claim files after a consumer complaint. It paid 126 refunds totaling $103,512.27 plus interest because NADA values had not been considered, and 115 title-fee refunds totaling $6,035.67 plus interest, and agreed to a $30,000 fine. The agreement concerns Rhode Island rules; total loss laws by state covers other states.
Sending a claim to Liberty Mutual
When we checked in November 2026, Liberty Mutual’s claims center offered filing and tracking a claim online, and its claims menu included an option to file a claim against a Liberty Mutual customer. If a claim is already open, send the diminished value demand in writing to the claims representative under that claim number. How to contact an auto insurer explains how to confirm the contact, and the demand letter guide lists what to send.
Evidence, and what to do if you disagree
For a repaired car, a diminished value appraisal documents the loss in value from the repair order, photos and comparable vehicles. For a totaled car, a total loss appraisal checks the comparables and adjustments in the insurer’s report, and how the appraisal clause works covers the policy route for a valuation dispute. Autoloss does not handle total-loss claims in Alabama, Connecticut, New Jersey, New York, Rhode Island, South Carolina or Wyoming. An appraisal is evidence, not a promise of payment, and Autoloss does not negotiate with insurers. See after your appraisal and how to file an auto insurance complaint for next steps, and filing a diminished value claim with any insurer for the shared steps. This page is general information, not legal advice.
Sources
- Hop v. Safeco Ins. Co. of Illinois, 2011 MT 215, 361 Mont. 510, 261 P.3d 981
- Lara v. First Nat’l Ins. Co. of America, No. 21-35126 (9th Cir. Feb. 11, 2022)
- Signor v. Safeco Ins. Co. of Illinois, No. 21-13148 (11th Cir. July 3, 2023)
- Skiffington v. Liberty Mut. Ins. Co., 93 Mass. App. Ct. 1 (2018)
- Trudgian v. LM General Ins. Co., 2024 COA 87
- Ke v. Liberty Mut. Ins. Co., No. 21-3248 (3d Cir. Jan. 10, 2023) (not precedential)
- Rhode Island DBR, Consent Agreement with Liberty Mutual Insurance Group (2017)
- Liberty Mutual: independent agents page, “What happened to Safeco?” (checked November 2026)
- Liberty Mutual: claims center (checked November 2026)
Common questions
Does Liberty Mutual pay diminished value?
It depends on your state and on whether you are claiming on your own policy or against a Liberty Mutual driver. The one appellate diminished value ruling we found, Hop v. Safeco (Mont. 2011), was procedural and did not decide whether the loss is owed.
My policy says Safeco. Does this page apply?
When we checked in November 2026, Liberty Mutual’s site said Safeco was acquired by Liberty Mutual in 2008 and the Safeco name is now retired. Two of the decisions above, Hop and Signor, name Safeco companies.
What is a condition adjustment?
A deduction some total-loss valuations make to reflect the difference between your car and the dealer-lot cars used as comparables. Courts in Lara (9th Cir. 2022) and Signor (11th Cir. 2023) ruled on adjustments of this kind under Washington and Florida law.
Is Autoloss affiliated with Liberty Mutual?
No. Autoloss is independent and is not affiliated with or endorsed by Liberty Mutual or Safeco. The names are used only to identify the insurers.
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Start here
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Not sure whether an appraisal will help?
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.