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State law · WA
Autoloss has an office in the Northwest, and you are welcome to visit if you would rather meet in person.
Washington is one of the more favorable states. Courts measure damage to a car by its before-and-after market value, and a 2022 published appellate decision allowed a claim for value lost after professional repairs. In Moeller v. Farmers (2011) the Supreme Court held that particular auto policy language covered diminished value, but results depend on each policy's wording and on proving real physical loss, not mere stigma.
Claim against the at-fault driver
Allowed by case law
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
Washington law
Third-party claim
Allowed by case law
Washington measures damage to personal property not destroyed by the before/after market-value difference. In Grothe v. Kushnivich (2022, published), the Court of Appeals held diminished value of a professionally repaired car is recoverable, citing Moeller's Court of Appeals decision, but barred double recovery. Grothe arose under a federal carrier statute applying Washington damages law.
Authority: Grothe v. Kushnivich, No. 39010-1-III (Wash. Ct. App. Dec. 6, 2022) (published); Moeller v. Farmers Insurance Co. of Washington, 173 Wn.2d 264, 267 P.3d 998 (2011)
First-party claim
Depends on your policy
Moeller held a Farmers policy promising repair or replacement with 'like kind and quality' covers diminution in value between pre-accident and post-repair condition, as the average consumer would read it. The Court distinguished covered diminished value (physical damage that cannot be fully repaired) from disfavored 'stigma' damages. In Heaphy (2003), State Farm conceded its UIM coverage included diminished value. Other policy wording may differ.
Authority: Moeller v. Farmers Insurance Co. of Washington, 173 Wn.2d 264, 267 P.3d 998 (2011); Heaphy v. State Farm Mutual Automobile Insurance Co., 117 Wn. App. 438, 72 P.3d 220 (2003), review denied, 150 Wn.2d 1037 (2004)
Case law
Washington Supreme Court · 2011
173 Wn.2d 264, 267 P.3d 998 (2011)
5-4: Farmers' policy language ('repair or replace ... with other of like kind and quality') covers diminution in value of a repaired car, and the class was properly certified.
Washington Court of Appeals, Division III · 2022
No. 39010-1-III (Wash. Ct. App. Dec. 6, 2022) (published)
Under Washington common law (applied through the federal Carmack Amendment), damages for property damaged but not destroyed are the before/after market-value difference; loss of use during repair and diminished value of the repaired car are recoverable, but no double recovery.
Washington Court of Appeals, Division II · 2003
117 Wn. App. 438, 72 P.3d 220 (2003), review denied, 150 Wn.2d 1037 (2004)
Because State Farm conceded its UIM property-damage coverage includes diminished value, the remaining dispute (whether and how much DV the car suffered) was a factual question for arbitration, not a class action.
RCW 4.16.080(2): Three-year limitation
Actions for taking, detaining, or injuring personal property must be commenced within three years.
RCW 4.16.040(1): Six-year limitation on written contracts
Actions on a written contract must be commenced within six years.
RCW 4.22.005: Effect of contributory fault
A claimant's own fault reduces damages proportionately but does not bar recovery (pure comparative fault).
RCW 46.29.090(1): Requirements as to policy or bond
Minimum limits: $25,000 per person, $50,000 per accident bodily injury, $10,000 property damage (required for driving by RCW 46.30.020).
Researched September 30, 2026. General information from an appraisal perspective, not legal advice.
Autoloss in WA
Autoloss has an office in the Northwest, and you are welcome to visit if you would rather meet in person.
We serve Washington 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.
