Depreciation of Labor & Materials is Needed to Determine ACV

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I have argued against those courts who claim insurers, when determining, ACV, should only depreciate materials and not labor. To reach such a conclusion those courts need to conclude that a house is built magically by materials only that never require the labor of a person to bring those materials together to make a home. In Thomas Accardi v. Hartford, No. 42A19, 373 N.C. 292, 838 S.E.2d 454, Supreme Court of North Carolina (February 28, 2020) the Supreme Court ruled with logic and common sense when asked to rule that ACV can only be determined by depreciation of materials and not the labor required to complete a repair.

ZALMA OPINION

Until technology creates a method to build a home without labor when determining ACV by using the common technique of determining replacement value and then depreciating that cost to reach ACV, it only makes sense to depreciate the full cost of the repair or replacement. The North Carolina Supreme Court’s decision is obvious. and those that rule labor cannot or should not be depreciated are illogical and a means to punish an insurer.