Sproull v. State Farm Fire & Casualty Co.

Plaintiff filed putative class action complaint alleging that insurer improperly depreciated labor costs when it calculated "actual cash value" of covered losses and that insurer concealed this practice from policyholders. Where Illinois's insurance regulations provide that the "actual cash value" of an insured, damaged structure is determined as "replacement cost of property at time of loss less depreciation, if any, and the policy does not itself define actual cash value, only the property structure and materials are subject to a reasonable deduction for depreciation, and depreciation may not be applied to the intangible labor component.(MOORE and BARBERIS, concurring.)