
Insurer guide · Rulings mostly on total loss
Diminished value claims with USAA
The one appellate decision we found that rules on diminished value under a USAA policy comes from Texas. In 2004 a Houston appeals court held that the Texas standard auto policy did not cover lost value after an adequate repair. Most other USAA rulings concern totaled cars: how they were valued, and whether taxes and fees were owed. A claim against a USAA driver rests on state law.
By the Autoloss team · Reviewed by Monica Fisher · Published
Member, or someone a member hit
USAA’s own policyholders claim under their policy, and the wording decides the claim. If a driver USAA insures hit you, you are a third-party claimant, and your state’s property damage law decides what you can recover from that driver. First-party vs third-party diminished value explains the difference. The cases below name the USAA company that issued each policy, such as USAA Casualty Insurance Company, USAA General Indemnity Company or Garrison Property and Casualty Insurance Company, which the Seventh Circuit described as a USAA subsidiary. Autoloss is independent and is not affiliated with or endorsed by USAA. The name is used only to identify the insurer.
Texas: Hassler v. USAA (2004)
A USAA policyholder brought a proposed class action asking for the diminished value of repaired vehicles. The trial court granted summary judgment for USAA, and the Texas Court of Appeals in Houston (First District) affirmed in a memorandum opinion. It followed American Manufacturers Mutual v. Schaefer, in which the Texas Supreme Court had held in 2003 that the Texas Standard Personal Auto Policy “affords no coverage to compensate an insured policyholder for diminished value of an adequately repaired vehicle.” In Hassler it was undisputed that the repairs were not “faulty, incomplete, or inadequate,” so Schaefer decided the case.
The point to take from it is narrow. The ruling covers a claim on the policyholder’s own coverage after a repair everyone agreed was adequate. It does not decide a claim against a driver USAA insures, and it does not address a repair that left the car short of its pre-loss condition. The Texas page covers both.
Georgia and Washington: two cases often cited, and what they decided
- Georgia: Carlson v. USAA (M.D. Ga. 2015). Georgia policyholders whose cars were repaired after water damage sued over diminished value. The federal court sent the case back to state court because USAA had not shown that more than $5 million was at stake. The order decided nothing about whether diminished value was owed. Georgia’s rule for first-party claims comes from the Georgia Supreme Court’s Mabry decision, covered in the State Farm guide.
- Washington: Schwendeman v. USAA Casualty (Wash. Ct. App. 2003). This case is sometimes described as a diminished value ruling. It is not. It concerned repairs with parts not made by the original manufacturer. The court affirmed the denial of class certification because whether a part met the policy’s “like kind and quality” standard had to be shown vehicle by vehicle. If your repair used aftermarket parts, the repair order is what shows which parts were used.
Total-loss rulings involving USAA companies
These decisions are about totaled cars, not diminished value after repair. They are listed separately because the questions are different: how actual cash value was calculated, and what it includes.
| Court and year | Case | What the court decided |
| U.S. Court of Appeals, Fifth Circuit (Louisiana law), 2023 | Sampson v. USAA | Vacated certification of a class of USAA insureds whose CCC valuations were below NADA values. The plaintiffs had not shown why NADA, rather than another guide, measured actual cash value, so injury could not be proved class-wide. It did not decide that the CCC valuations were correct. |
| U.S. Court of Appeals, Sixth Circuit (Michigan law), 2024 | Marchek v. USAA | Reversed dismissal. Because the policy defined actual cash value by what it would cost to buy a comparable vehicle, the plain language “plausibly requires” USAA to pay sales tax and mandatory fees. This was a ruling at the pleading stage. |
| U.S. Court of Appeals, Seventh Circuit (Illinois law), 2021 | Coleman v. Garrison Property and Casualty | Affirmed dismissal in a nonprecedential order. Actual cash value was the most the insurer would pay, and Illinois regulations require sales tax and transfer fees only if the insured buys a replacement and documents the cost within 30 days of settlement. |
| Texas Supreme Court, 2024 | USAA Casualty v. Letot | Reversed certification of a class of claimants whose cars USAA reported to the state as salvage before they accepted payment. Letot, a third-party claimant, kept her individual damages claim. The ruling concerns the salvage report, not the valuation. |
| U.S. Court of Appeals, Eighth Circuit (Arkansas law), 2026 | Falasco v. USAA Casualty | A jury had found that USAA breached the policy and awarded $71,363.95 for a 1973 Porsche lost in a fire. The appeals court affirmed summary judgment for USAA on bad faith: relying on the CCC valuation was not shown to be bad faith, even though the owner disputed the comparables. One judge dissented. |
Read together, these cases show that the result often turns on the policy’s definition of actual cash value and on the state’s regulations. None of them describes how USAA values cars today. Disputing comparables and condition adjustments explains how to check a valuation report.
Regulator actions on USAA total-loss claims
- Oregon, 2020. In a consent order, the Department of Consumer and Business Services found that from 2010 to February 2020 USAA Casualty sent 53,393 total-loss notices that left out statements Oregon requires. One of them tells owners that, if they cannot buy a vehicle for the amount offered, they may find a comparable vehicle themselves. USAA Casualty was ordered to stop and to pay a $50,000 civil penalty.
- Washington, 2026. On 30 September 2026 the Office of the Insurance Commissioner announced a $140,000 fine against USAA Casualty for auto claim-handling violations. The office said that after reviewing two years of total-loss settlements for missing taxes and fees, the company paid 158 claims totaling $88,241.
Both concern the rules in one state. Total loss laws by state sets out what each state requires.
Sending a claim to USAA
When we checked in November 2026, USAA’s claims center said a claim can be reported on usaa.com or in the USAA Mobile App, and that members can follow it, contact the adjuster and upload documents in My Claims Center. It also had a third-party section for people who are not USAA members but were in an accident with one. If a claim is already open, send the diminished value demand in writing to the adjuster under that claim number. How to contact an auto insurer explains how to confirm the contact, and the demand letter guide lists what to include.
Evidence, and what to do if you disagree
For a repaired car, a diminished value appraisal documents the loss from the repair order, photos and comparable vehicles. A typical Autoloss report costs $250–$350, and the claim review that comes first is free. For a totaled car, a total loss appraisal checks the insurer’s valuation; Autoloss does not handle total-loss claims in Alabama, Connecticut, New Jersey, New York, Rhode Island, South Carolina or Wyoming. Either report is evidence, not a promise of payment. Autoloss does not negotiate with insurers. If you cannot agree, see after your appraisal and how to file an auto insurance complaint. The steps shared by every insurer are in filing a diminished value claim with any insurer. This page is general information, not legal advice.
Sources
- Hassler v. United Services Auto. Ass’n, No. 01-01-01018-CV (Tex. App.—Houston [1st Dist.] Jan. 29, 2004) (mem. op.)
- Carlson v. United Services Auto. Ass’n, No. 4:15-cv-6 (M.D. Ga. Mar. 30, 2015)
- Schwendeman v. USAA Cas. Ins. Co., 116 Wn. App. 9 (2003)
- Sampson v. United Services Auto. Ass’n, No. 22-30351 (5th Cir. Oct. 6, 2023)
- Marchek v. United Services Auto. Ass’n, No. 23-1908 (6th Cir. Oct. 11, 2024)
- Coleman v. Garrison Prop. & Cas. Ins. Co., No. 20-1480 (7th Cir. Mar. 10, 2021) (nonprecedential)
- USAA Cas. Ins. Co. v. Letot, No. 22-0238 (Tex. May 24, 2024)
- Falasco v. USAA Cas. Ins. Co., No. 25-2632 (8th Cir. Aug. 18, 2026)
- Oregon DCBS, In re USAA Casualty Ins. Co., Consent Order No. INS-20-0047 (July 20, 2020)
- Washington Office of the Insurance Commissioner, news release, Sept. 30, 2026
- USAA: claims center (checked November 2026)
Common questions
Does USAA pay diminished value?
It depends on your state and on whether you are a USAA member claiming on your own policy or someone claiming against a USAA driver. The one appellate ruling we found, Hassler (Tex. App. 2004), held that the Texas standard policy did not cover lost value after an adequate repair.
I am not a USAA member. Can I claim against a USAA driver?
That is a third-party claim, and your state’s law decides what you can recover from the at-fault driver. USAA’s claims center had a section for non-members when we checked in November 2026. Check the page for your state.
Do the total-loss cases apply to my repaired car?
No. They concern how a totaled car is valued and what the payment includes. A repaired car raises the separate question of diminished value.
Is Autoloss affiliated with USAA?
No. Autoloss is an independent appraisal company and is not affiliated with or endorsed by USAA. The name is used only to identify the insurer.
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Start here
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