Court finds against labor decline on ‘actual cash value’ payment

Insurance Matters

By Don R. Sampen

Don R. Sampen is a member of the appellate practice group of Clausen, Miller P.C., where he focuses on appellate, commercial and insurance-related litigation. He also teaches insurance law at Loyola University Chicago School of Law. His column appears twice monthly.

Posted November 9, 2021 10:30 AM

Updated November 9, 2021 1:40 PM

The Illinois Supreme Court recently held that, where an insured under a property policy is entitled to receive reimbursement for an insured loss on an actual cash value basis, and the policy itself does not define “actual cash value,” the amount to be paid is the replacement cost of the property at the time of loss less depreciation, but that depreciation is not to be taken on labor costs.The case is Sproull v. State Farm Fire & Casualty Co., 2021 IL 126446 (Sept. 23). The insured, Jarrett Sproull, was …

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