In Re: State Farm Fire & Casualty Co., No. 16-3185 (8th Cir. 2017)Annotate this Case
Plaintiff filed a putative class action, alleging that State Farm's practice of deducting "labor depreciation" from estimated replacement cost in determining actual cash value breached the insurance contract. The Eighth Circuit reversed the district court's denial of State Farm's motion to dismiss and certify a class. Although the court did not rule out the possibility that State Farm's use of the estimating methodology tool would produce an unreasonable estimate of the actual cash value of some partial losses, this issue may only be determined based on all the facts surrounding a particular insured's partial loss. Therefore, there were no predominant common facts at issue. Furthermore, the district court's order upholding premature classwide discovery was vacated. The court remanded with directions to dismiss the complaint and held that State Farm's petition for writ of mandamus was moot.