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State law · TN
Tennessee courts measure car damage either by reasonable repair cost or, if repairs cannot substantially restore the car's function, appearance and value, by the drop in market value from just before to just after the crash. The Court of Appeals has said an owner cannot collect both repair costs and post-repair lost value. Claims against your own insurer under a standard collision policy were rejected in 2002.
Claim against the at-fault driver
Limited
Claim against your own insurer
Depends on your policy
Time limit to sue for property damage
3 years
Insurance regulator
Reviewed by Monica Fisher, Owner, Licensed Auto Appraiser and Court Expert Witness — appraisal perspective, not legal advice
Last reviewed
Tennessee law
Third-party claim
Limited
Against an at-fault driver, the Court of Appeals (quoting GEICO v. Bloodworth, 2007) says damages are either repair cost or the before-and-after-accident market value difference, 'not both,' and that post-repair decrease in value is not a separate recognized element. An owner whose car cannot be substantially restored by repair may instead claim the before/after value drop, which is a question of fact.
Authority: Grimes d/b/a Madison Street Motors v. Hancock, No. M2011-01940-COA-R3-CV (Tenn. Ct. App. June 26, 2012); Government Employees Insurance Co. v. Bloodworth, No. M2003-02986-COA-R10-CV, 2007 WL 1966022 (Tenn. Ct. App. 2007)
First-party claim
Depends on your policy
In Black v. State Farm (2002) the Court of Appeals held a collision policy capping payment at the lower of actual cash value or repair cost is unambiguous and does not cover diminished value after adequate repairs. Other policy wording, or uninsured-motorist property-damage claims (the setting reported for Bloodworth), may be treated differently; that could not be confirmed from the Bloodworth opinion itself.
Authority: Black v. State Farm Mutual Automobile Insurance Co., 101 S.W.3d 427 (Tenn. Ct. App. 2002); Government Employees Insurance Co. v. Bloodworth, No. M2003-02986-COA-R10-CV, 2007 WL 1966022 (Tenn. Ct. App. 2007)
Case law
Tennessee Court of Appeals · 2002
101 S.W.3d 427 (Tenn. Ct. App. 2002)
A collision policy limiting liability to the lower of actual cash value or cost of repair/replacement is unambiguous; insureds whose cars were adequately repaired could not recover diminished value in addition to repair cost.
Tennessee Court of Appeals · 2012
No. M2011-01940-COA-R3-CV (Tenn. Ct. App. June 26, 2012)
Restating Bloodworth: the measure of damage to personal property is repair cost if repair substantially restores function, appearance and value; otherwise the before/after market-value difference. It is not both, and post-repair decrease in value is not a separate element in Tennessee.
Status: treatment unclear: Docket number from CourtListener metadata. Also held an owner has no duty to repair before claiming damages.
Tennessee Court of Appeals · 2007
No. M2003-02986-COA-R10-CV, 2007 WL 1966022 (Tenn. Ct. App. 2007)
As quoted in Grimes: the measure is repair cost or the pre/post-accident market value difference, not both, and post-repair diminished value is not a recognized separate element in Tennessee.
Status: treatment unclear: Could not open the Bloodworth opinion itself; URL is Grimes, which quotes it. Reported by a law-firm page to be a UM class action. The legacy '01C2325' is likely the trial-court number; not verified.
Tenn. Code Ann. § 28-3-105(1): Three-year limitation for injuries to property
Actions for injuries to personal or real property must be commenced within three years from accrual.
Tenn. Code Ann. § 55-12-102: Financial responsibility minimums
Tennessee's minimum liability limits are $25,000 per person, $50,000 per accident for injury, and $25,000 property damage (as stated by the Department of Revenue).
Researched September 30, 2026. General information from an appraisal perspective, not legal advice.
Autoloss in TN
We serve Tennessee 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.
