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State law · WY

Wyoming diminished value claims

No Wyoming appellate decision squarely decides diminished value after repair. Wyoming's general rule for a damaged vehicle measures loss as the difference in value before and after the damage, which supports a claim against an at-fault driver in principle, but the issue is unsettled. Claims against your own insurer depend on the policy. Tort suits must be filed within four years.

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  • Claim against the at-fault driver

    Unsettled

  • Claim against your own insurer

    Unsettled

  • Time limit to sue for property damage

    4 years

Reviewed by Monica Fisher, Owner, Licensed Auto Appraiser and Court Expert Witness — appraisal perspective, not legal advice

Last reviewed

Wyoming law

What Wyoming law says about diminished value

Third-party claim

Against the at-fault driver’s insurer

Unsettled

The Wyoming Supreme Court has said the measure of damage to a vehicle not totally destroyed is the difference in fair market value immediately before and after the injury, with repair cost accepted as proof, and quoted the Restatement rule allowing for any difference between original value and value after repairs. No Wyoming case was found that expressly awards or rejects post-repair diminished value.

Authority: Meredith GMC, Inc. v. Garner, 78 Wyo. 396, 328 P.2d 371 (1958); Wilcox v. Herbst, 75 Wyo. 289, 295 P.2d 755 (1956); Wyo. Stat. § 1-3-105(a)(iv)(B)

First-party claim

Against your own insurer

Unsettled

No Wyoming statute, regulation, bulletin or appellate decision on diminished value under your own collision coverage was found. The answer depends on the wording of your policy.

Case law

Key Wyoming court decisions

Meredith GMC, Inc. v. Garner

Wyoming Supreme Court · 1958

78 Wyo. 396, 328 P.2d 371 (1958)

The measure of damages for personal property not entirely destroyed is the difference in value immediately before and after the injury; for a vehicle, cost of repair is an accepted alternative way to prove damage. The court quoted Restatement of Torts § 928, which allows repair cost 'with due allowance for any difference between the original value and the value after repairs.'

Status: treatment unclear: Fire damage to a truck in a repair shop, not a collision. The Restatement language is quoted, not a holding on post-repair diminished value. No later case overruling it was found, but later history was not fully checked.

Read the decision

Wilcox v. Herbst

Wyoming Supreme Court · 1956

75 Wyo. 289, 295 P.2d 755 (1956)

Quoting a treatise, the court described the measure for a damaged automobile as cost of repair plus loss of use pending repair, and more generally the difference in fair market value immediately before and after the injury.

Status: treatment unclear: Car struck a horse. Relevant only to the general measure of damages.

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Miller v. Campbell County

Wyoming Supreme Court · 1995

901 P.2d 1107 (Wyo. 1995)

An inverse-condemnation case about homes evacuated over underground gas; held the collateral source rule does not apply and discussed fair-market-value compensation for takings. It has nothing to do with vehicles.

Read the decision

Statutes and rules

  • Wyo. Stat. § 1-3-105(a)(iv)(B): Limitation of actions other than recovery of real property

    Actions for injuring personal property must be brought within four years after the cause of action accrues. Actions on a written contract: ten years (§ 1-3-105(a)(i)).

  • Wyo. Stat. §§ 31-9-405(b), 31-9-102(a)(xi), 31-4-103(a): Motor vehicle liability policy minimum limits

    Owners must carry liability coverage of at least $25,000 per person and $50,000 per accident for bodily injury and $20,000 for property damage.

Deadlines and minimum coverage

Time limit for a property-damage lawsuit
4 years (Wyo. Stat. § 1-3-105(a)(iv)(B)). Four years for injury to personal property. A first-party claim on a written policy is contractual (ten years under § 1-3-105(a)(i)), but the policy may set a shorter suit deadline.
Minimum liability insurance
$25,000 per person / $50,000 per accident bodily injury; $20,000 property damage. The at-fault driver’s property-damage limit can cap what their insurer pays.
If your claim stalls
You can file a complaint with the Wyoming Department of Insurance.
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Autoloss in WY

Appraisals for Wyoming vehicles

We serve Wyoming 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.

  1. 1

    Free claim review

    Tell us about the vehicle and the Wyoming claim.
  2. 2

    Send photos and repair records

    Final invoice, photos, and the insurer’s claim details.
  3. 3

    Receive your appraisal

    Reviewed by Monica Fisher, with a custom demand letter.
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Have a Wyoming diminished value claim?

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.

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