Diminished Value Appraisal in
Colorado

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 recognize recovery for the difference in fair market value before and after the damage. See Trujillo v. Wilson (1948) and Larson v. Long (1923).

First-party (collision/comprehensive DV)

Generally no. Colorado does not imply DV coverage into collision forms unless the policy expressly provides it. See Lovell v. State Farm (10th Cir. 2006).

UM/UIM and UMPD

Colorado’s UM/UIM statute protects bodily injury losses. Optional UMPD applies when no collision coverage is carried. Whether DV is covered depends on policy wording; most exclude it.

Key Colorado Law & Authority

• DV measure: Trujillo v. Wilson; Larson v. Long.
• First-party DV exclusion: Lovell v. State Farm.
• Statute of limitations: C.R.S. § 13-80-101 — 3 years for motor-vehicle property damage.
• Comparative negligence: C.R.S. § 13-21-111 — recovery barred if you are ≥50% at fault.
• Small Claims: C.R.S. § 13-6-403 — jurisdiction up to $7,500.
• Crash reports: Official requests via CDOT Crash Data.

Types of Diminished Value

• Immediate DV: The drop in value right after the crash before repairs.
• Repair-related DV: Loss tied to repair deficiencies (frame variance, panel gaps, paint mismatch).
• Inherent (stigma) DV: Market stigma that remains even after proper repairs—the most common type of Colorado diminished value claim.

What You Need to Document

• Police/Crash report: Request through the Colorado DOR/CDOT crash data portal.
• Photos: Pre-loss (if available), scene, and post-repair photos (VIN & odometer included).
• Repair records: Estimates, invoices, and parts details (OEM vs aftermarket).
• Market data: Title/history and local comparable listings or auction results.
• Professional DV appraisal quantifying residual loss with Colorado comps.

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

1. Confirm the claim path: Third-party (most common), first-party (rare, usually excluded), or optional UMPD (policy-dependent).
2. Complete repairs. DV is measured after repairs.
3. Compile evidence. Crash report, photos, repair file, comps, and history.
4. Order a DV appraisal. A SnapClaim Report provides Colorado-specific comps and methodology.
5. Send a formal demand. Attach appraisal and exhibits; cite Trujillo and Larson.
6. Negotiate with market data. Counter insurer “formula” methods with real comparables.
7. Escalate if needed: File regulator complaint with Colorado Division of Insurance, pursue small claims, or sue in District Court.

Why a Professional Appraisal Is Crucial

Insurers often undervalue DV using rough formulas. A SnapClaim Diminished Value Report uses Colorado-market comparables, transparent adjustments, and expert review—built to withstand negotiation or court. If your vehicle is a total loss, request a Fair Market Value Appraisal. You’re protected by our Money-Back Guarantee. Compare state rules at Diminished Value State Laws.