Diminished Value Appraisal in
Colorado

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Filing a Diminished Value Claim in Colorado: What You Need to Know

Last updated: August 15, 2025

After a Colorado crash, your vehicle may be worth less even after quality repairs. That loss in market value is called diminished value (DV). This Colorado-focused guide explains when Colorado diminished value is recoverable, what evidence you need, a step-by-step filing process (with deadlines), and why using a professional appraisal from SnapClaim helps you resolve claims faster and for the correct amount.

Does Colorado Allow Diminished Value Claims?

Third-party (liability) DV: Yes. Colorado courts have long recognized recovery for the difference in fair market value before and after the damage—the core DV measure. This is the legal foundation for most Colorado diminished value claims. See the Colorado Supreme Court in Trujillo v. Wilson (1948) (difference in value immediately before and after, plus reasonable efforts to restore) and Larson v. Long (1923) (depreciation from an accident is an element of damages). Numerous Colorado law-firm resources also confirm third-party DV is recoverable when properly documented.

First-party (your own collision/comprehensive) DV: Generally not paid under standard collision forms unless the policy expressly provides it. The Tenth Circuit (applying Colorado law) upheld dismissal of a claim seeking to imply DV coverage into collision policies in Lovell v. State Farm (10th Cir. 2006).

UM/UIM and UMPD: Colorado’s UM/UIM statute primarily protects against bodily injury losses. A separate statute allows optional UM property damage (UMPD) when you do not carry collision coverage (request-only), but whether DV is covered depends on policy language; most first-party forms exclude DV. See C.R.S. § 10-4-609 (UM/UIM) and C.R.S. § 10-4-610 (UMPD on request for policies without collision).

New to DV? Start with our Diminished Value Overview.

Key Colorado Law & Authority

Recognition & measure of DV: Trujillo v. Wilson, 117 Colo. 430, 189 P.2d 147 (Colo. 1948) (difference in value before vs. after + reasonable restoration efforts); Larson v. Long, 74 Colo. 152, 219 P. 1066 (1923) (depreciation evidence admissible; diminution is an element of damages).
First-party DV not implied into collision: Lovell v. State Farm, 466 F.3d 893 (10th Cir. 2006).
Statute of limitations (motor-vehicle property damage): C.R.S. § 13-80-101(1)(n)(I) — 3 years from accrual for property damage arising out of the use or operation of a motor vehicle.
Comparative negligence: C.R.S. § 13-21-111 — recovery reduced by your fault; barred at ≥50% fault.
Small Claims (useful for DV disputes): C.R.S. § 13-6-403 — jurisdiction up to $7,500 exclusive of interest/costs; or file in County/District Court for higher amounts.
Pattern jury guidance on property loss: Colorado Civil Jury Instructions, Chapter 6 (Part B) (measure of damages for loss/destruction of personal property): Colorado Judicial Branch PDF.

Types of Diminished Value

Immediate DV: The drop in value right after the crash before repairs.
Repair-related DV: Loss tied to repair deficiencies (e.g., structural variance, panel gaps, paint mismatch, non-OEM parts).
Inherent (residual) DV: Market stigma that remains even after proper repairs—the most common basis for Colorado diminished value claims.

For background on DV categories and methods, see MWL: Third-Party Diminution in Value and NAIC’s research on DV impacts.

What You Need to Document

Police/Crash report: Colorado’s official crash records are maintained in the DOR “DRIVES” system. CDOT explains that individual crash reports must be requested through the Department of Revenue or the investigating agency. See CDOT Crash Data page for process: CDOT Crash Data & FAQs. Many cities (e.g., Aurora) sell reports via CrashDocs: Aurora Police – Crash Reports/Online Reporting.
Photos: Pre-loss (if available), scene damage, and post-repair—cover all damaged and adjacent panels, with VIN and odometer shots.
Repair records: Initial and supplemental estimates, final invoice, parts list (OEM vs. aftermarket), frame specs, paint materials sheets.
Vehicle & market data: VIN/options, mileage, ownership/title, accident-history report, and local comparable listings/auction data.
Professional DV appraisal: An independent post-repair appraisal quantifying residual and repair-related loss with transparent comps — essential for a defensible Colorado diminished value claim. Order a SnapClaim Diminished Value Report.

If your vehicle is a total loss, use our Fair Market Value (Total Loss) Appraisal instead.

How to Obtain Colorado Crash Reports

Colorado uses the DR3447 crash report. CDOT notes that officers submit reports to the Department of Revenue (DOR), which maintains the official record in DRIVES. For individual reports, request from DOR or the investigating agency: CDOT Crash Data (process & contacts). Cities often provide online reporting and report purchase portals (e.g., Aurora Police).

Step-by-Step: Filing a Diminished Value Claim in Colorado

Confirm the claim path.
- Third-party DV: Typical for DV—claim against the at-fault driver’s liability insurer for the difference between pre-loss FMV and post-repair FMV (supported by Trujillo/Larson). This is the most common route for a Colorado diminished value recovery.
- First-party (collision): Most policies exclude DV unless explicitly added; Lovell confirms no implied DV under collision.
- UM/UIM/UMPD: UM/UIM mainly covers bodily injury; optional UMPD can apply when no collision, but DV coverage depends on policy wording.
Complete repairs (or obtain final repair documentation). DV is measured post-repair against pre-loss condition.
Compile evidence. Crash report, photos, full repair file, title/history, and market comps that show stigma after repair.
Order a professional DV appraisal. Get a defensible valuation built on Colorado-market comparables and recognized damage principles — the cornerstone of a successful Colorado diminished value claim. SnapClaim DV appraisal.
Send a formal demand to the liability carrier. Attach the appraisal and clearly state the DV theory (inherent and/or repair-related) and requested amount; index exhibits (A, B, C…).
Negotiate using market data. Address mileage/condition adjustments, comparable selection, and insurer “formula” methods (e.g., 17c) by emphasizing market-verified comps and expert methodology—no single formula is binding under Colorado law.
Escalate if needed.
- Regulator help: Contact the Colorado Division of Insurance (DORA) Consumer Services (see doi.colorado.gov; phone/email are listed in DOl’s annual complaint report) or NAIC’s State Insurance Departments directory.
- Small Claims Court: Consider filing if negotiations stall and your DV is ≤ $7,500 (C.R.S. § 13-6-403). Bring your appraisal, crash report, repair invoices, photos, and comps.
- County/District Court: For higher amounts or contested liability; consult a Colorado attorney experienced in auto property damage/DV.
Track deadlines. For motor-vehicle property damage (including DV), the limitations period is 3 years from accrual (C.R.S. § 13-80-101(1)(n)(I)). Comparative negligence may reduce or bar recovery under C.R.S. § 13-21-111.

Colorado-Specific Tips to Strengthen Your Claim

Use Colorado comps. Include local dealer/private-party listings and recent auction data to show the real market discount for an accident on Colorado titles.
Document repair quality. Frame/unibody measurements and paint-meter readings help establish (or rule out) repair-related DV.
Be explicit on theory. State whether your claim seeks inherent DV, repair-related DV, or both—and tie each to numbered exhibits. Clear labeling helps insurers and courts evaluate a Colorado diminished value demand quickly.
Organize your file. A labeled exhibit stack (A, B, C…) with a cover index speeds insurer review, regulator inquiry, or a court hearing.

Why Using a Professional Appraisal Is Crucial

Insurers often rely on rough formulas that understate real-world market impact. A SnapClaim Diminished Value Report uses Colorado-market comparables, transparent adjustments, and expert review—built to withstand negotiation, Small Claims, or trial. If your vehicle is totaled, use our Fair Market Value (Total Loss) Appraisal. You’re protected by our Money-Back Guarantee Policy.

References & Resources

Recognition & measure of DV: Trujillo v. Wilson, 117 Colo. 430, 189 P.2d 147 (Colo. 1948); Larson v. Long, 74 Colo. 152, 219 P. 1066 (1923).
First-party DV not implied: Lovell v. State Farm, 466 F.3d 893 (10th Cir. 2006).
Statute of limitations (motor-vehicle BI/PD): C.R.S. § 13-80-101(1)(n)(I).
Comparative negligence: C.R.S. § 13-21-111.
Small Claims jurisdiction: C.R.S. § 13-6-403; CO Courts FAQ: Small Claims FAQs.
Crash reports (official process): CDOT Crash Data (DOR is official custodian); example local portal: Aurora Police Crash Reports.
Consumer/regulator help: Colorado Division of Insurance (DORA) Consumer Services (see doi.colorado.gov); NAIC directory: State Insurance Departments.
Background on DV: MWL 50-State Diminution-in-Value Survey.
SnapClaim internal resources:

Recover Diminished Value After an Accident in Colorado

If your car was damaged in a Colorado crash, it may have lost market value even after repairs. That loss is called diminished value, and under Colorado law you may be entitled to recover it from the at-fault driver’s insurance. SnapClaim makes the process simple: get a free diminished value estimate, a certified Colorado appraisal report, and a ready-to-send demand letter — all within minutes. No guesswork. No delays.

"After my accident in Denver, I didn’t realize how much value my car had lost. SnapClaim gave me everything I needed — a certified Colorado diminished value report and demand letter — in less than an hour. I got my claim paid quickly."