Lori McDonnell v. State Farm…

Summary

The court affirmed that Alaska's mandatory insurance appraisal statute does not apply to uninsured-motorist personal-injury claims because the statute concerns valuation of tangible property losses, not the valuation of bodily injuries or legal claims. It held that uninsured-motorist claims generally are governed by the three-year contract limitations period and accrue when the insurer allegedly breaches the policy, such as by denying the claim or clearly refusing payment. The court also held that State Farm's two-year contractual limitation is enforceable only upon a showing of prejudice and cannot begin before the insured's claim accrues.