Stuart v. State Farm Fire and Casualty Co., No. 16-3784 (8th Cir. 2018)
Annotate this Case
The Eighth Circuit affirmed the district court's order certifying a class of Arkansas homeowners who alleged that State Farm improperly withheld amounts for labor depreciation when making payments under their insurance policies. The court held that the district court did not abuse its discretion by concluding that plaintiffs' claims shared a common, predominating question of law. In this case, plaintiffs' theory was that State Farm violated its contractual obligations by depreciating both materials and labor when calculating ACV, thereby reducing the size of their ACV payments.
The court also held that the district court properly noted that the class members' claims were generally small and unlikely to be pursued individually; that concentrating the claims in a single forum was desirable; and that it did not anticipate unreasonable difficulty in managing the class action. The court explained that the fact that some plaintiffs may be unable to succeed on their claims did not necessarily mean that they lack standing to sue. Finally, the court modified the certification order to exclude those subject to another settlement from the class definition.
Court Description: Kelly, Author, with Wollman and Erickson, Circuit Judges] Civil Case - class certification. District court certified a class of Arkansas homeowners who alleged that State Farm improperly withheld amounts for labor depreciation between 2008 and 2013 when calculating the actual cash value (ACV)of damaged property. It was not an abuse of discretion for the district court to conclude the insured shared a common, predominating question of law. This court's decision in In Re: State Farm Fire & Casualty Co., 872 F.3d 567 (8th Cir. 2017) (applying Missouri law) does not control the claims at issue because Arkansas explicitly prohibits insurer from depreciating labor costs when using the formula to calculate ACV, and the district court's conclusion that common questions predominate over individualized issues was not an abuse of discretion. State Farm's argument that some plaintiffs cannot demonstrate injury-in-fact does not mean they lack standing to sue and go to the merits of the claims, not before the court on the certification question. The certification order is amended to exclude those subject to a different class action.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.