On July 24, 2025, the Seventh Circuit Court made a significant ruling regarding Progressive Insurance’s methods for valuing totaled cars in Indiana. The court reversed a previous class action decision that challenged the company’s approach, which involved adjustments based on projected sales.
The case originated with two Indiana policyholders, Heather Schroeder and Misty Tanner. They argued that Progressive’s use of "Projected Sold Adjustments" lowered the payouts for their totaled vehicles, violating their auto insurance policy. This method was part of a valuation system created by Mitchell International and J.D. Power, intended to reflect typical negotiations between buyers and sellers when only list prices were available.
According to Progressive’s standard Indiana auto policy, the company is responsible for covering "sudden, direct and accidental loss" from collisions, based on the car’s "actual cash value" at the time of the loss, minus any applicable deductible. The policy allows Progressive to use various estimating systems, including third-party software, to determine loss amounts.
In February 2019, Schroeder’s 2018 Toyota Corolla was declared a total loss after an accident. Progressive valued it at $14,576, which included a $655 reduction due to Projected Sold Adjustments. After applying a $500 deductible, Schroeder accepted the settlement offer. Similarly, Tanner’s 2013 Chrysler 200 was totaled in July 2020, with Progressive initially valuing it at $7,062 and later adjusting it upward by $500 after Tanner disputed the valuation.
Schroeder filed a lawsuit in May 2022, claiming that the use of Projected Sold Adjustments breached Progressive’s obligation to pay the actual cash value. Tanner joined the lawsuit in April 2023, and they sought to represent a class of Indiana policyholders affected by this valuation method. The Southern District of Indiana certified their class, believing that the issue of whether the adjustments violated the policy was common to all members.
However, the Seventh Circuit disagreed. The court stated that Progressive’s policy did not prohibit the use of these adjustments as long as the final payout reflected the actual cash value defined under Indiana law. The court concluded that determining whether Progressive underpaid any individual policyholder would require a detailed examination of each car’s value and comparable sales, making class action treatment inappropriate.
As a result of this ruling, the case will return to the district court, but now only individual claims will be considered. This decision underscores the complexities of insurance valuations and the challenges policyholders may face when disputing their claims.