Illinois Panel: Insurer May Not Depreciate Labors Costs In Calculating ACV

(July 28, 2020, 11:35 AM EDT) -- MOUNT VERNON, Ill. — In answering a certified question in a coverage dispute arising from wind damage, an Illinois appeals court on July 24 held that a homeowners insurer cannot depreciate the "intangible" cost of labor when determining the actual cash value of its insured's loss as defined under the policy's Dwelling coverage (Jarret Sproull v. State Farm Fire and Casualty Company, No. 5-18-0577, Ill. App., 5th Dist., 2020 Ill. App. LEXIS 500)....