Arizona Supreme Court

Gerald Walker v. Auto-Owners Insurance Comp

September 27, 2022

Summary

The court answered two certified questions concerning the calculation of actual cash value under the Walkers' homeowners insurance policy. It held that the policy adopted the replacement-cost-less-depreciation method, which permits depreciation of materials but not future labor costs, and that the broad evidence rule did not apply to this policy. The court further held that the broad evidence rule may apply under other policies whose terms do not prescribe a different valuation method.