Sigler v. Geico Casualty Co., No. 19-2272 (7th Cir. 2020)Annotate this Case
Sigler totaled his 2001 Dodge Ram and filed a claim with GEICO, his auto insurer, for the loss. GEICO paid him for the value of the car, adjusted for depreciation, minus his deductible. Sigler claims he is entitled to sales tax and title and tag transfer fees for a replacement vehicle, though he did not incur these costs. He filed a proposed class action against GEICO seeking damages for breach of contract. The district court dismissed the suit, holding that neither the GEICO policy nor Illinois insurance law requires payment of these costs when the insured does not incur them.
The Seventh Circuit affirmed. The premise of Sigler’s suit, that sales tax and title and tag transfer fees are always part of “replacement cost” in a total-loss claim regardless of whether the insured incurs these costs, misreads the policy and Illinois insurance regulations. GEICO’s policy does not promise to pay sales tax or title and tag transfer fees; the Illinois Administrative Code requires a settling auto insurer to pay these costs only if the insured actually incurs and substantiates them with appropriate documentation.