Last updated: August 13, 2025

If your vehicle was damaged in a Georgia crash and later repaired, it may still be worth less than before. That lost market value is called diminished value (DV). This guide explains when DV is recoverable in Georgia, the evidence you need, how to file step-by-step (including state-specific options to escalate), key deadlines, and why a professional appraisal from SnapClaim strengthens your case.

Does Georgia Allow Diminished Value Claims?

Third-party DV (claim against the at-fault driver’s insurer): Yes. Georgia tort law allows recovery for diminution in value as part of property damage—the difference between the vehicle’s fair market value just before the crash and after repair.

First-party DV (claim under your own policy): Uniquely, Georgia requires carriers to assess and pay inherent diminished value when the policy promises to pay for “loss” and the insurer repairs the vehicle. In State Farm Mut. Auto. Ins. Co. v. Mabry, the Georgia Supreme Court held that an insurer’s obligation to pay for “loss” includes any post-repair diminution in value; the carrier must evaluate DV using an appropriate methodology. See Mabry. This principle was later reiterated beyond autos in Royal Capital Dev., LLC v. Maryland Casualty Co., where the Court explained that Mabry speaks generally to the measure of damages (cost of repair and/or diminution in value). See Royal Capital.

New to DV? Start here: Diminished Value Overview.

Key Georgia Law & Authority

• First-party diminished value: State Farm v. Mabry (Ga. 2001) — Insurers must evaluate and, when warranted, pay inherent DV on first-party physical damage claims under policies promising to pay for “loss.”
• Measure of damages: Royal Capital (Ga. 2012) — Confirms that diminution in value is a recognized measure of damages in Georgia in addition to cost of repair.
• Statute of limitations (property damage): O.C.G.A. § 9-3-31 — Generally 4 years for injuries to personal property (includes DV).
• Consumer escalation: Georgia Office of Commissioner of Insurance (OCI) — complaint portal and helpline for claim handling disputes: File a Consumer Insurance Complaint | Insurance Resources | Contact.

Types of Diminished Value Recognized

• Immediate DV: Value loss immediately after the crash and before repairs (mostly used by insurers/experts, less by consumers).
• Repair-related DV: Loss caused by sub-optimal repairs (non-OEM parts, structural/frame variance, paint mismatch).
• Inherent (residual) DV: The stigma loss remaining after quality repairs because the vehicle now has an accident history—central to Georgia DV claims and expressly evaluated under Mabry.

Required Documentation

• Crash report: Obtain online via LexisNexis BuyCrash (BuyCrash). If investigated by the Georgia State Patrol, you can request through the DPS Open Records Unit (DPS Open Records).
• Photos: Pre-loss (if available), post-crash, and post-repair images capturing all damaged/repaired panels.
• Repair records: Initial and supplemental estimates, final invoices, parts list (OEM vs aftermarket), frame/unibody measurements, refinish materials sheets.
• Vehicle & market data: VIN, trim/options, mileage (pre/post), service history, ownership/title status, and comparable sales/listings in Georgia markets.
• Professional appraisal: An independent DV report quantifying inherent and repair-related DV using transparent methodology and local comps — order a SnapClaim DV appraisal.

If the vehicle is a total loss, obtain a Fair Market Value (Total Loss) Appraisal instead.

How to Obtain Georgia Crash Reports

Most agencies submit reports to the statewide portal: BuyCrash. Some GSP reports can be requested via the Department of Public Safety’s Open Records process: DPS Open Records Request. For public crash data trends, see GDOT’s dashboard: GDOT Crash Data & Reporting.

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

1. Confirm the claim path: first-party vs. third-party.
   • First-party: With your own insurer under comprehensive/collision. In Georgia, Mabry requires carriers to evaluate inherent DV when the policy promises to pay for “loss.”
   • Third-party: Against the at-fault driver’s liability policy; you claim the post-repair reduction in fair market value.
2. Assemble evidence. Crash report, photos (damage and post-repair), complete repair documentation, and vehicle condition records.
3. Order a professional DV appraisal. Use SnapClaim to obtain a fast, defensible valuation grounded in Georgia market data. This is critical under Mabry’s requirement for “appropriate methodology.”
4. Send a formal demand. Provide your appraisal and exhibits (photos, estimates, invoices, comps). State the DV amount and the valuation theory (pre-loss vs. post-repair FMV).
5. Negotiate with data. Be ready to address mileage/condition adjustments, repair quality, and comparable selection. Counter any formulaic reductions with market-verified comps and methodology from your appraisal.
6. Escalate if needed.
   • Georgia OCI complaint: If claim handling appears unfair, file with the regulator: Complaint Portal (contacts: phone/email).
   • Magistrate (Small Claims) Court: For disputes up to $15,000 (jurisdictional cap). See O.C.G.A. § 15-10-2 and your county’s magistrate site (e.g., DeKalb Magistrate FAQs).
   • State or Superior Court: For claims exceeding $15,000 or when more formal litigation is appropriate.
7. Track deadlines. Georgia’s property-damage statute of limitations is generally 4 years from accrual (O.C.G.A. § 9-3-31). Contract claims may have policy-specific notice and proof-of-loss requirements; read your policy.

Georgia-Specific Tips to Strengthen Your Claim

• Use Georgia-based comps. Reflect how local buyers discount for accident history in your metro (Atlanta, Savannah, Augusta, etc.).
• Document repair quality. Include frame specs and paint meter readings if available; this supports or rules out repair-related DV.
• State the theory precisely. Identify whether your claim is for inherent DV, repair-related DV, or both; tie each to evidence.
• Keep an exhibit stack. Label attachments (A, B, C…) to streamline adjuster or court review.

Why Using a Professional Appraisal Is Crucial

Carriers closely scrutinize Georgia DV claims and may apply rough formulas that understate real-world market impact. A SnapClaim appraisal uses Georgia-market comparables, transparent adjustments, and expert review—designed to stand up under Mabry’s “appropriate methodology” standard. If your vehicle is totaled instead of repaired, use our Fair Market Value (Total Loss) Appraisal. You’re also covered by our Money-Back Guarantee Policy.

• Order a Diminished Value Report
• Diminished Value Overview
• Fair Market Value (Total Loss) Appraisal
• Money-Back Guarantee Policy
• Diminished Value State Laws

References & Resources

• State Farm Mut. Auto. Ins. Co. v. Mabry, 274 Ga. 498 (2001): Opinion (Justia) | FindLaw
• Royal Capital Dev., LLC v. Maryland Casualty Co., 291 Ga. 262 (2012): Opinion (Justia) | FindLaw
• Statute of Limitations — Injuries to Personalty: O.C.G.A. § 9-3-31
• Georgia OCI — Consumer Assistance: File a Complaint | Insurance Resources | Contact
• Crash Reports: LexisNexis BuyCrash | DPS Open Records (GSP) | GDOT Crash Reporting
• Magistrate (Small Claims) Jurisdiction: O.C.G.A. § 15-10-2 | Example county guidance: DeKalb Magistrate FAQs
• SnapClaim internal resources for Georgia claimants:
  • Order a Diminished Value Report
  • Diminished Value Overview
  • Fair Market Value (Total Loss) Appraisal
  • Money-Back Guarantee Policy
  • Diminished Value State Laws