Wyoming
Diminished Value Overview
In Wyoming, a vehicle involved in a not at fault accident may lose market value even after repairs are completed. When another driver is responsible for the accident, Wyoming law allows you to pursue compensation for that loss in value from the at fault driver’s insurance company as part of your property damage claim.
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01
Statute of Limitations
Wyoming allows twfouro years from the date of the accident to pursue a diminished value claim.
02
Third-Party Claims
Diminished value is recoverable when another driver is at fault, and you can file against the at-fault party’s insurance.
03
First-Party and Uninsured Motorist
Most Wyoming auto policies exclude diminished value under first party coverage. Uninsured and underinsured motorist coverage do not apply to diminished value claims.
04
Small Claims Court Limit
Wyoming small claims court allows cases up to $6,000.
Wyoming Diminished Value Law
Wyoming courts recognize that damages to personal property are measured by the actual loss in value caused by the injury. When a vehicle is damaged due to another party’s negligence and repairs do not fully restore it to its pre loss market value, the resulting diminution in value may be recoverable as part of a third party property damage claim. Wyoming follows the principle that damages must compensate for real economic loss and be proven with reasonable certainty.
Meredith GMC, Inc. v. Garner, 328 P.2d 371 (Wyo. 1958)
The Wyoming Supreme Court cited with approval Restatement of Torts § 928, recognizing that when personal property is damaged but not totally destroyed, damages may include the difference in value before and after the injury or, at the plaintiff’s election, the reasonable cost of repair together with an allowance for any remaining loss in value after repairs are completed. This framework supports recovery for residual diminished value when repairs fail to fully restore market value.
Aetna Casualty & Surety Co. v. Langdon, 624 P.2d 240 (Wyo. 1981)
The court explained that Wyoming law allows damages to be calculated using either the cost of repairs method or the decrease in market value method, depending on the circumstances of the loss. The appropriate measure is determined by which method most accurately reflects the actual economic loss suffered. When repairs alone do not fully compensate for the loss, diminished value may be included as part of the damage calculation.
Reposa v. Buhler, 770 P.2d 235 (Wyo. 1989)
The Wyoming Supreme Court held that the proper measure of damages for injury to personal property is the loss in market value, and that damages must be proven with a reasonable degree of certainty. While exact precision is not required, speculative or conjectural damages are not recoverable. This standard permits recovery for diminished value when credible evidence establishes a post repair loss in market value.