
Insurer guide · Rulings in one to three states
Diminished value claims with Progressive
Two state supreme courts have ruled on diminished value under Progressive policies: Delaware in 2001 and Florida in 2002. Both held that the policy before the court did not require payment for lost value after an adequate repair. Both were claims by Progressive’s own policyholders. A claim against a driver Progressive insures rests on state law instead.
By the Autoloss team · Reviewed by Monica Fisher · Published
Two claims that are easy to confuse
A Progressive policyholder asking for diminished value under collision coverage is making a contract claim, and the policy wording decides it. Someone hit by a Progressive policyholder is making a claim against that driver, and state law on property damage decides it. The court decisions below are almost all of the first kind. First-party vs third-party diminished value has the detail. Autoloss is independent and is not affiliated with or endorsed by Progressive; the name is used only to identify the company.
Florida: Siegle v. Progressive (2002)
The Florida Supreme Court was asked whether a collision policy that let the insurer repair or replace the vehicle “with other of like kind and quality” also required payment for diminished market value after a repair that restored the car’s performance, appearance and function. The court answered no. This was a policyholder’s claim against her own insurer. It did not address what an at-fault driver owes; the Florida page covers that separately.
Delaware: O’Brien v. Progressive Northern (2001)
The Delaware Supreme Court considered policies from three insurers, Progressive Northern among them, and concluded that the repair-or-replace language was not ambiguous and “does not contemplate payment for diminution of value.” The insurer’s obligation, the court said, was to return the vehicle to substantially its pre-accident physical, operating and mechanical condition.
Both rulings interpret the policy forms that were in front of those courts. They are not statements about how Progressive handles claims, and they do not control in other states.
A Delaware third-party case: Progressive Gulf v. Doughty (2014)
This case shows a different route. A driver whose car was hit in Delaware took a diminished value claim against the other driver’s insurer, Progressive Gulf, to the Delaware Insurance Department’s automobile arbitration panel, which awarded him $7,979.31. The Delaware Superior Court reversed because the other driver’s policy had been issued in Virginia, and the panel’s rules excluded claims involving out-of-state policies. The judge wrote that he expressed no opinion on the validity of the diminished value claim. The case is useful for what it shows about procedure in Delaware, not as a ruling on whether diminished value is owed. See the Delaware page.
Filing with Progressive
When we checked in October 2026, Progressive’s claims page let customers report a claim by logging in or through its app, and had a separate option for people not insured by Progressive to report or view a claim. Once a claim number exists, the demand goes to the assigned claims representative. Keep it in writing. The demand letter guide lists what to include, and how to contact an auto insurer explains how to confirm where to send it.
Supporting the figure
Whichever kind of claim you have, the insurer will want to know how the amount was reached. A diminished value appraisal sets out the vehicle’s value before the loss and after repair, with the comparable vehicles used. If the insurer’s figure comes from a formula, insurer offer vs independent appraisal explains how the two approaches differ. Autoloss answers questions about how its report was prepared but does not negotiate the claim.
If the claim is not resolved
Options include asking for a written explanation, a complaint to your state’s insurance department, and, in a third-party claim, a court claim against the at-fault driver. After your appraisal and how to file an auto insurance complaint describe each. The general filing guide has the steps common to all insurers, and the Allstate guide covers another company with rulings in a few states.
Common questions
Does Progressive pay diminished value in Florida?
In Siegle v. Progressive (Fla. 2002), the Florida Supreme Court held that the collision policy before it did not require payment for diminished value after a full repair. That concerned a policyholder’s own coverage. A claim against an at-fault driver is a different question; see the Florida page.
Can I claim diminished value if a Progressive driver hit me?
That is a third-party claim against the driver, and it depends on your state’s law rather than on the policy rulings above. Check the page for your state.
Is Autoloss affiliated with Progressive?
No. Autoloss is an independent appraisal company and is not affiliated with or endorsed by Progressive. The name is used only to identify the insurer.
Keep reading
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Diminished value claims with Nationwide
A 1965 Virginia ruling, an Ohio loaner-car case and a Kentucky parts case.
Start here
Filing a diminished value claim with any insurer
The six steps that do not change from one insurer to the next.

Not sure whether an appraisal will help?
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