We have written before about class actions involving disputes about automobile insurers’ valuations of wrecked vehicles deemed a total loss. See, e.g. , Eleventh Circuit reverses dismissal of class action disputing State Farm’s calculation of “actual cash value,” holding required appraisal process not a condition precedent to suit (March 29, 2024). The Seventh Circuit recently reversed class certification in such a case, rejecting the district court’s conclusion that the insurer breached a “methodological” duty and holding that the question of whether the insurer paid “actual cash value” presented individual issues that outweighed common questions. Schroeder v. Progressive Paloverde Ins. Co. , --- F.4th ----, No. 24-1559, 2025 WL 2083855 (7th Cir. July 24, 2025).
Under the policy at