Diminished Value Appraisal in
Georgia

Last updated: August 18, 2025

Georgia is the leading state for diminished value (DV) law. The Georgia Supreme Court has explicitly held that insurers must pay for inherent diminished value under standard auto policies in certain cases. If your car is worth less after an accident, even with quality repairs, you may be entitled to recover that loss. This guide explains when Georgia diminished value is recoverable, the key case law, what to document, filing deadlines, and why a professional SnapClaim appraisal gives you the strongest negotiating position.

Does Georgia Allow Diminished Value Claims?

Third-party (at-fault driver’s insurer)

Yes. Georgia recognizes DV as a valid measure of damages. In State Farm Mut. Auto. Ins. Co. v. Mabry, 556 S.E.2d 114 (Ga. 2001), the Georgia Supreme Court held that an insurer must pay for inherent diminished value when repairs do not fully restore a vehicle’s pre-loss value. This makes Georgia the most claimant-friendly DV state in the U.S.

First-party (your own policy)

Yes, in many cases. In Mabry, the Court confirmed that under standard policy language, inherent DV is covered as part of the insurer’s obligation to return the vehicle to its pre-loss condition. Unless the policy explicitly excludes DV, Georgia policyholders may pursue first-party DV claims.

UM/UIM and UMPD

Georgia requires UM/UIM coverage unless waived in writing. UM property damage can apply if the at-fault driver is uninsured or underinsured. DV claims under UM property damage depend on policy terms, but Mabry supports their inclusion absent clear exclusion.

Key Georgia Law & Authority

• Recognition of DV: Mabry — inherent DV covered under standard auto policies.
• Measure of damages: Cost of repair or diminution in value; both may apply if repairs do not restore pre-loss value.
• Statute of limitations: O.C.G.A. § 9-3-31 — 4 years for damage to personal property (including DV).
• Comparative negligence: O.C.G.A. § 51-12-33 — modified comparative negligence; recovery barred if plaintiff is 50% or more at fault.
• Small claims: Georgia Magistrate Court hears small claims up to $15,000 (see Georgia Magistrate Courts Council).
• Insurance complaints: File with the Georgia Office of Commissioner of Insurance.

Types of Diminished Value in Georgia

• Immediate DV: Loss in value right after the accident, before repairs.
• Repair-related DV: Loss caused by poor-quality or incomplete repairs.
• Inherent (stigma) DV: Residual loss in resale value even after quality repairs — the most common type of Georgia diminished value claim.

What You Need to Document

• Crash report: Required for injury, death, or property damage of $500+. Obtain through the Georgia BuyCrash portal.
• Repair records: Initial estimates, supplements, invoices, and calibration/frame data.
• Photos: Pre- and post-repair photos (VIN and odometer included).
• Market data: Vehicle history report and comparable Georgia sales/auctions.
• Professional DV appraisal using Georgia comps.

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

1. Confirm the claim path. In Georgia, both third-party and first-party DV claims may be allowed.
2. Complete repairs. DV is measured post-repair.
3. Order a professional DV appraisal. SnapClaim’s report uses Georgia-market comparables and accepted methodology.
4. Send a written demand. Attach the appraisal, crash report, repair docs, and photos. Cite Mabry to support recoverability.
5. Negotiate with evidence. Georgia has no set DV formula; market-grounded appraisals carry the most weight.
6. Escalate if needed: File a complaint with the Georgia Insurance Commissioner, pursue small claims court (≤ $15,000), or file in State/Superior Court for higher amounts.

Why a Professional Georgia DV Appraisal Helps

Georgia insurers often undervalue DV using formulas like the “17c” method, which courts have not adopted as binding. A SnapClaim Diminished Value Report uses Georgia-market comps, transparent adjustments, and expert methodology to maximize your recovery. If your vehicle was totaled, request a Fair Market Value Appraisal. You’re protected by our Money-Back Guarantee. For other states, see Diminished Value State Laws.