AUTOBODY DIRECTORY
HomeGuides › State Farm's Auto Claims, on the Record

State Farm's Auto Claims, on the Record

Short answer: State Farm's only public repair-shop contract is the 2015 Select Service agreement, a court exhibit. Where no pricing agreement exists it makes the shop charge the lowest of three rates. Pennsylvania's 2025 consent order directed $55,000. State Farm won the aftermarket parts case.

By Anthony Braswell for Quorum Industries LLC, The Autobody Directory · Updated 2026-09-01 · How this was written, and what the machine may not do

How this page was produced: Researched, drafted and checked with AI assistance under human direction, and signed off by the named author. How this site is written

State Farm's Select Service agreement governs what a repair shop may charge State Farm, and a lawsuit put the clause on the record.

The document is Exhibit A in Pulera Collision et al. v. State Farm, a 2016 Illinois case brought by three Wisconsin shops. It is a 2015 form, public only because litigation made it public: Section 5.a obliges the shop not to "disclose, distribute, or reproduce any part or section of the Agreement to any other person or organization, unless required by law."

The clause, in full

Section 4.a reads:

"Repair Pricing. Provider agrees to estimate and bill for repairs based on a pricing agreement between Provider and State Farm. If no pricing agreement exists, Provider agrees to charge the lower of the: (1) Most recent labor rates and paint and materials pricing information submitted by Provider to State Farm through State Farm's survey process; or (2) Current labor rates and paint and materials pricing identified through State Farm's survey process; or (3) Labor rates and paint and materials pricing offered to or agreed to with any other insurer."

Two things about that clause are routinely reported wrong.

The first is the qualifier. The lowest-of ladder is not unconditional. It applies only "If no pricing agreement exists." Where State Farm and the shop have negotiated a pricing agreement, that agreement governs and limbs (1) to (3) never engage. An account that drops those five words describes a different contract.

The second is what the ladder does when it engages. Limb (3) is a most-favored-nation term: a discount granted to any carrier extends automatically to State Farm. Limb (2) makes State Farm's own survey one of the three ceilings, and the lowest of the three governs. Section 5.j then requires the shop to "maintain current pricing and capacity information within the B2B Auto Repair Facility Survey Form." The shop is an input to the survey and is bound by its output.

Section 5.g completes it. The shop "agrees not to disclose, discuss, or share labor rate or pricing information with other repairers, and acknowledges this activity may be construed as illegal price fixing." That statement of law is defensible: horizontal rate discussion among competitors is genuine antitrust exposure. The structure is still worth naming. The shop feeds the survey, is priced by the survey, and is discouraged from comparing notes with the only parties who could say whether the result is right.

Repairer Driven News quotes the same clause independently, which is why it appears here at all. State Farm contested the shops' reading of it. Its answer "denies that there were errors in the prevailing rate"; it accepted that it had not told the shops in advance of the cut but denied wrongdoing in that; and its counsel told the court that the conduct alleged "is either explicitly permitted under the contract or it's not even addressed in the contract" and that "None of these plaintiffs has identified a single customer who was steered away."

What else the shop signs

From the same agreement:

The same document records what State Farm undertakes. Section 1.a: "Provider acknowledges that vehicle owners have freedom of choice when selecting a repair facility." Section 2.g: "State Farm agrees to review Provider's final repair bill as submitted and agrees to process payment in a timely manner," subject to a reservation of "the right to withhold payment if the accuracy of the final repair bill is in question or there is a repair quality issue that needs to be resolved." Section 5.l provides for payment direct to the shop, and Section 5.m for State Farm to pay legally imposed sales, use and similar excise taxes.

This is the 2015 form. Current terms are not public: the B2B Select Service portal is login-gated and publishes no eligibility criteria or obligations.

What is established: the regulators

Pennsylvania. The Insurance Department examined State Farm Mutual Automobile Insurance Company for July 1, 2022 to June 30, 2023 and issued its report and consent order on January 16, 2025. The order directs that "Respondent shall pay Fifty-Five Thousand Dollars ($55,000.00) in settlement of all violations contained in the Report."

The collision sample: "The 16 violations noted were based on 10 files, resulting in an error ratio of 10%." Total loss: "The 17 violations noted were based on 12 files, resulting in an error ratio of 12%." Worst was first-party medical referred to a peer review organization, where all 11 files were reviewed and "The twenty violations noted were based on ten files, resulting in an error ratio of 91%."

The recurring defect across four auto claim categories is appraisal integrity. Adding the per-category lines gives twenty-one violations of 31 Pa. Code 62.3, cited where "The Company failed to provide an appraisal that meets all applicable standards per statute," and twenty-two of 63 P.S. 861(b), cited because "The appraisals were missing the appraiser's license number."

Two examiner observations sit outside the counts. Status letters are automatically generated and do not specifically describe the delay reason, listing eight possible reasons instead. And in two files reviewed, the company prepared original appraisals without including damage that was known at the time.

North Carolina, and it cuts the other way. The Department of Insurance examined State Farm for 2009 through 2012 and reported on May 2, 2014. On automobile claims it found nothing: "All payments issued by the Companies were deemed to be accurate. Deductibles were correctly applied and depreciation taken was reasonable." Payment averaged 10.0 days on automobile physical damage and 12 calendar days on total losses. Violations were found, but in homeowners underwriting, where 59 of 100 policies contained 66 rating errors. The exam tested payment accuracy, deductibles, depreciation and total-loss settlement, and found them compliant. It is also twelve to seventeen years old, and it did not examine labour rates.

Delaware, a clean negative control. Examining State Farm Fire and Casualty and State Farm Mutual Automobile for January 1, 2017 to March 31, 2022, Delaware's examiners "randomly selected adjusters to verify their licensing, utilizing the verification service from the Department in coordination with the NAIC. No exceptions were noted." That report records exceptions elsewhere, among them complaint-log accuracy, responses to Department complaints and missing statute-of-limitations notices, but none on adjuster licensing. The same check applied to three Travelers companies for 2020 to 2022 produced a different answer: "There were 16 claims adjusters not licensed from their applicable date of licensing and the claim loss date." Same regulator, same verification service, different results. Where the record clears State Farm, it clears it.

Kansas, on the numbers. The Insurance Department's 2024 complaint index compares a company's share of complaints with its share of the business written in the state, where 1.00 means the two are equal. On automobile, State Farm Mutual Automobile Insurance Company drew 111 complaints on an 18% share, an index of 0.62. Its principal auto entity attracted proportionally fewer complaints than its size predicts. State Farm Fire and Casualty's much smaller Kansas auto book scored 2.84 on 30 complaints at a 1% share, a denominator too small to carry weight in either direction.

Texas, and a carrier that is not named. Senate Bill 458 of the 89th Legislature requires personal auto and residential property policies to contain an appraisal provision. The bill analysis says, in a single sentence: "However, some companies in Texas have attempted to remove this clause and in 2015, one of the largest personal auto insurance carriers successfully filed and removed the appraisal process from policies for partial vehicle loss." It names no insurer. We are not claiming State Farm is the carrier that sentence describes; the legislature recorded the conduct and named nobody, trade commentary attributes it to State Farm, and the primary document does not. The legislature's answer was to make the provision mandatory rather than optional.

What is established: the courts

State Farm won the defining aftermarket parts case. In Avery, an Illinois jury awarded $456,180,000 on a breach of contract claim and the trial judge added $130 million in disgorgement and $600 million in punitive damages on a consumer fraud claim, a total of $1,186,180,000, on a theory that State Farm specified non-OEM crash parts not of like kind and quality. The appellate court reversed the disgorgement award as a double recovery, bringing the total to $1,056,180,000. The Illinois Supreme Court reversed in August 2005, holding that "State Farm's specification of non-OEM parts did not constitute a breach of any of the relevant individual policy forms," and construing "like kind and quality" to mean "sufficient to restore a vehicle to its pre-loss condition," not OEM equivalence. It also reversed the consumer fraud judgment and class certification. Avery is often cited in the trade as though State Farm lost. State Farm won. The U.S. Supreme Court declined to review the decision, and a later attempt to reinstate the original claim was rejected.

The body shop antitrust theory was dismissed and affirmed. Shops in Mississippi, Indiana and Utah alleged State Farm used "faulty methods and outright manipulation of data to generate 'market rates' that are well below the real market rates," that its survey was "more sham than survey," that other carriers followed, and that insurers collectively steered work away from non-compliant shops. The Eleventh Circuit affirmed dismissal on March 6, 2020 of the Mississippi shops' antitrust claims and of their state law claims, and revived two tortious interference claims that ran against the Progressive defendants, not State Farm. The parallel Indiana and Utah actions were disposed of on jurisdiction rather than on the merits. Against State Farm, the survey-methodology theory was litigated and it lost.

Georgia is where State Farm lost outright. In State Farm v. Mabry, 274 Ga. 498 (2001), the Georgia Supreme Court affirmed an order holding that "the policies issued by State Farm obligate it to compensate its policyholders for that loss of value, notwithstanding repairs that return the vehicle to pre-loss condition in terms of appearance and function, if the repairs do not return the vehicle to its pre-loss value." Under that order State Farm must assess diminished value on Georgia first-party physical damage claims without the insured asking. We located no equivalent standing order in any other state, and did not survey all fifty.

Total loss, decided on procedure, not merits. State Farm's total loss valuations came from Audatex, which applied a downward "typical negotiation" adjustment. Per the opinion, "Audatex assumed that 'most people' negotiate with used-car dealers to get a reduced sales price as compared to the advertised one." A district court certified roughly 90,000 Tennessee policyholders. Sitting en banc on April 24, 2026, the Sixth Circuit reversed that certification, holding that individual valuation questions predominate and that the damages formula stripped State Farm of a substantive right to present vehicle-specific evidence. Judge Gibbons dissented. The court did not decide whether the adjustment was lawful. The class was destroyed, not the claim itself.

What is established: parts, vendors and money

State Farm suspended specification of all non-OEM crash parts in 1999, calling it temporary. It ended the suspension effective October 16, 2023, telling shops it would "sunset the current suspension of all non-OEM crash parts, when available and appropriate, for both policyholder and claimant estimates," covering bumper components, lighting, radiator supports and outer sheet metal, requiring CAPA or NSF certification, and excluding exterior parts carrying the OEM or vehicle name or logo, per the memo as reported.

State Farm's replacement parts page says "The final choice as to which parts will actually be used in repairs rests with you, the vehicle owner," then adds: "Should the use of those other parts increase the repair cost, you will be expected to pay the difference." Its repair services page pairs "You have the ability to select a repairer of your choice that meets your vehicle repair needs" with "You may be responsible for any amounts not agreed to by State Farm." Both are accurate. Together they describe a choice free in one direction only.

On vendors, State Farm told Select Service shops that "All Select Service repairers will be required to use the CCC Perform package for all estimates uploaded to State Farm no later than April 1, 2021," per Repairer Driven News. On September 8, 2025 it widened the choice to CCC ONE or Mitchell Cloud Estimating. Two options, not three.

The money frames the rest. State Farm reported 2025 net income of $12.9 billion, net worth of $170 billion, a property-casualty underwriting gain of $1.5 billion after losses above $6 billion in 2024, and an auto combined ratio of 93.5 against roughly 104 in 2024, per Insurance Journal. On NAIC 2025 data State Farm remained the largest private passenger auto insurer at 18.64% to Progressive's 18.60%. On S&P Global Market Intelligence data for the twelve months to March 31, 2026, Progressive passed it, about $70.2 billion to $68.7 billion, the first time since 1942 that State Farm has not ranked first. S&P's caveat belongs with that figure: the trailing-twelve-month calculation required estimating results for two of Progressive's New Jersey-domiciled subsidiaries that had not filed quarterly statements with the NAIC, which is why "publicly available information will actually show that State Farm continues to hold a slight lead over Progressive on a trailing-12-month basis."

A mutual with no shareholders, $170 billion of net worth and a 93.5 auto combined ratio is not a company under financial pressure, and nothing in those figures supports a theory that it must underpay claims to survive.

On March 26, 2026 State Farm announced auto rate cuts averaging roughly 10% across 40 states and a one-time $5 billion cash-back dividend. Its stated reason, quoted exactly: "Declining auto repair costs and fewer collisions have contributed to rate reductions for customers, making quality coverage more affordable." Source.

What is alleged, and only alleged

We are not saying State Farm underpays claims as a matter of course. We are saying the 2015 contract sets the ceiling in the words quoted above, and that a regulator found twenty-one appraisal violations in one examination. Nothing else in this section has been found true of State Farm's auto claims handling by any court or regulator. One matter below carries a jury finding on a single homeowners claim against a different State Farm entity, and says so.

Hale v. State Farm alleged that State Farm spent "more than $3.5 million" through undisclosed advocacy groups on Lloyd Karmeier's 2004 campaign for the Illinois Supreme Court in order to obtain the reversal of Avery, pleaded as racketeering. State Farm settled for $250 million on September 4, 2018, after the jury had been selected and before opening statements, and denied any wrongdoing in settling. Spokesman Jim Camoriano said the settlement "is made simply to bring an end to the entire litigation" and "to avoid protracted litigation and appeals that could continue for several more years." The allegations were never tried and no court has found them true. Both halves belong in the same sentence.

The Hurricane Katrina whistleblower case ended the same way. It is a homeowners matter against a different entity, and it appears here because it is the one place a jury has made a finding against a State Farm company on a claims practice. In 2013 a federal jury in Mississippi found, on a single home, that State Farm Fire and Casualty had avoided covering a policyholder's wind losses by blaming the damage on storm surge, which the federal flood program covered. The broader pattern was never tried. In August 2022 State Farm Fire and Casualty paid $100 million to the federal government with no admission of wrongdoing, saying only: "The parties are pleased to bring an end to this 16-year litigation."

On total loss valuation, State Farm agreed to pay $15.6 million to settle Chadwick in the Eastern District of Arkansas, covering roughly 37,000 class members at an average of $489, with a final approval hearing set for July 15, 2026, whose outcome we could not confirm. "State Farm denies the allegations and stopped using Audatex in October 2021." The successor case, Brewer in North Carolina, targets the CCC ONE Market Valuation Report and an "Average Private condition" adjustment applied to comparable vehicles, alleging a 5.5% reduction for the named plaintiff and 4% to 9% for the class. State Farm had not responded when the case was reported. The vendor changed and the label changed; the pleaded theory, an adjustment applied to the comparables rather than the loss vehicle, did not.

On labour rates, a Financial Times P&C Specialist investigation relayed by Repairer Driven News reported that a centralised State Farm team "reviews estimates prepared by third-party shops as well as its own staff adjusters," and that "Internal emails and documents show that estimates are sometimes revised even after approval by staff adjusters, with cuts to the time allowed for labor, certain repair procedures, and prices for parts." The same reporting describes cuts of as much as 20% in eight months, one Midwest shop moving from $74 to $70 to $64 in ten months, and a policy change in multiple states between late 2024 and early 2025 adding "a clause stating that the insurer can determine labor and repair costs based on what it decides is a 'reasonable rate.'" If accurate, that last item matters most: it moves the rate from something measured to something decided. The investigation itself is paywalled and was not read for this article.

At the Collision Industry Conference on April 22, 2026, K&M Collision vice president Michael Bradshaw said "We've seen a dramatic reduction in labor rates across the country." Speaking of a carrier whose name he said he would not repeat, he described an appraiser visiting the shop, scope being agreed at the vehicle, and the appraisal then going to "a centralized internal review team, and those internal review teams remove countless operations without discussion with the body shop, without engagement with the body shop, without review of the proper documentation, without any explanation, or without a name of the individual within the central review team being attached." On his account each removal forces a fresh supplement and a fresh ten to fourteen day clock, so that "what actually was discussed and agreed upon at the vehicle now takes 45-60 days." He also said "State Farm has intentionally written the appraisal clause language out of policies in states where it's not a regulatory requirement," a qualifier that belongs with the claim. In a FenderBender survey reported in the same article, 57% of 230 respondents said State Farm had reduced the labour rates offered to their shop without explanation. State Farm's Property and Casualty Claims Director Ed Mondragon interrupted him for naming the company, saying he had breached the conference's conduct expectations and antitrust rules, and, per the report, "State Farm representatives provided no other response to the conversation." In a WSOC-TV Action 9 segment reported on May 13, 2026, State Farm said: "State Farm is there for our customers and pays what we owe within the terms of our auto policy. If a body shop has concerns, we encourage them to reach out directly to us so that we can have a conversation."

Set that beside the rate-reduction release. In March 2026 State Farm attributed price cuts partly to "Declining auto repair costs." In the same months, 57% of the 230 shops answering the FenderBender survey said State Farm had cut their rates without explanation. Whether repair costs fell in the market or fell in what State Farm pays is the unresolved question, and no source we could verify resolves it.

What we could not establish

This is the most important section: everything above was checked, and these were not.

The Pennsylvania headline number. A figure of 106 violations circulates for that exam. Two reads of the report returned different aggregates, and a targeted re-read confirmed the document states no grand total anywhere. The per-category counts above reproduced identically. The total did not, so none appears here.

Whether State Farm is the carrier in the Texas bill analysis. The legislature recorded the conduct and named nobody. Texas Department of Insurance form filings would settle it. Bradshaw's allegation that the clause was removed in states where it is not required could not be confirmed against any policy form.

The final outcome of Pulera. One ruling is documented. At a June 9 motion to dismiss hearing, reported in September 2017, Lake County 19th Circuit Judge Luis Berrones dismissed the declaratory judgment and common law fraud counts with prejudice and allowed the steering and breach of contract counts to proceed, per the same report that quotes the pricing clause. What became of the surviving counts is not established here, and neither is the disposition of the case as a whole.

Details we cut rather than hedge. A specific dollar reduction attributed to the Clippinger plaintiff, a count of judges joining the dissent, a quote attributed to attorney Erica Eversman about carriers pricing just below State Farm, specific North Carolina rate figures, and an allegation about calibrations performed in shop parking lots all failed to reproduce at the sources cited for them. None appear above.

A misattribution worth naming. The "you may be responsible for any amounts not agreed to" language has been attributed to AAA. It is State Farm's, on State Farm's own repair services page. We have read no AAA claims page.

The California accusation is not an auto matter. California's Accusation and Order to Show Cause of May 4, 2026 concerns State Farm General Insurance Company, the California property subsidiary, and 2025 Los Angeles wildfire claims. Different entity, different line, unadjudicated pleading. Excluded for all three reasons.

Structure, lobbying and technology. The only holding-company chart we located is undated and stale, so nothing is said here about which entity a Texas policyholder actually contracts with. Federal lobbying totals rest on secondhand reporting. And no source establishes which of CCC's AI estimating or total-loss modules State Farm licenses or deploys. Adjacency to a vendor is not evidence of use.

Two narratives that are not findings. We do not claim that State Farm's survey depresses labour rates. That theory was pleaded, dismissed, and the dismissal affirmed on appeal. That State Farm bought a seat on the Illinois Supreme Court was pleaded and settled, with no admission and no adjudication. Both are routinely reported as established. Neither is.

Sources we could not fully read. Three named documents sit behind a barrier, and each is named rather than glossed over. State Farm's B2B Select Service portal was read on 2026-09-01 and returns a login gate: it publishes tool navigation and no eligibility criteria or obligations, which is why the 2015 court exhibit remains the only Select Service text on this page. CollisionWeek's September 8, 2025 report was read on 2026-09-01 and is paywalled below its opening paragraphs; the sentence quoted here sits in the free portion, and nothing behind the wall is relied on. The Financial Times P&C Specialist investigation behind the labour-rate reporting is paywalled and was not read at all: everything attributed to it here is a relay through Repairer Driven News, and it is the thinnest load-bearing evidence on this page.

Corrections

This page is new. The corrections below were made to its own draft before publication, not after a reader complained, because a page that only shows its wins is not evidence of anything. Each entry says what the draft said, what it says now, and why it changed. Every one of them ran against State Farm before it was fixed.

2026-09-01, the Avery damages figures. The draft said an Illinois jury awarded roughly $1.19 billion and that the figure was cut on appeal to roughly $1.06 billion. The opinion says something different. The jury awarded $456,180,000 on the breach of contract claim; the trial judge added $130 million in disgorgement and $600 million in punitive damages on the consumer fraud claim, for a total of $1,186,180,000; and the appellate court reversed only the $130 million as a double recovery. The draft credited a jury with a number the bench largely built. Corrected to the opinion's own figures.

2026-09-01, the "most people" assumption. The draft attributed to State Farm the assumption that most people negotiate a used car price down from the advertised one. The Sixth Circuit's en banc opinion attributes it to the vendor: "Audatex assumed that 'most people' negotiate with used-car dealers to get a reduced sales price as compared to the advertised one." Re-attributed to Audatex and quoted directly.

2026-09-01, the Bradshaw appraisal-clause quotation. The draft quoted Michael Bradshaw as saying "State Farm has intentionally written the appraisal clause language out of policies" and stopped there. The sentence he spoke ends "in states where it's not a regulatory requirement." Cutting it made the allegation materially broader than the allegation actually made, about a company that will read this page. The full sentence is now quoted and the qualifier is flagged in the text as belonging to the claim. This was the most serious fairness defect found in the draft.

2026-09-01, the FenderBender survey. The draft said "a majority of surveyed shops" reported cuts, which turns one self-selecting trade poll of 230 respondents into an industry finding, and it set that in the same sentence as State Farm's rate-reduction announcement, inviting a causal inference the page never states. It now reads 57% of 230 respondents, the juxtaposition is broken into separate sentences, and the page says plainly that no source we could verify resolves which way the causation runs.

2026-09-01, the fifty thousand dollar liability cap. The draft quoted Section 5.p's aggregate cap without its two qualifiers: the cap is mutual, binding both parties, and the same clause carves out the indemnification obligation in Section 5.o, Hold Harmless. Quoted bare, a bilateral limit reads as a shield one party holds over the other. Both qualifiers restored in the same bullet as the quotation.

2026-09-01, the Kansas complaint index. The draft omitted it entirely. Kansas publishes a 2024 complaint index in which State Farm Mutual Automobile Insurance Company drew 111 automobile complaints on an 18% share of the business written, an index of 0.62, meaning proportionally fewer complaints than its size predicts. That is a regulator-published, auto-specific figure running in State Farm's favour, and leaving it out was the worst omission found in the draft. Added, together with State Farm Fire and Casualty's 2.84 on 30 complaints at a 1% share and the small-denominator caveat that goes with it, so the entry is not one-sided in either direction.

Related

Sources

Every document above was read on 2026-09-01, and every quotation on this page was re-pulled from its primary source and string matched against the fetched text before publication. Anything that would not re-verify was cut rather than softened, and the cuts are named in "What we could not establish" and in "Corrections" rather than left to be noticed. This page is a record of documents, not legal advice.

General consumer information: not legal, insurance, or financial advice. Requirements, coverage, and practices vary by state, policy, and manufacturer.

Run a body shop? Your shop likely already has a page here, built from public records. Check it and claim it free: verifying only ever adds.
What does claiming add? It's free ›

More guides

ADAS Calibration Explained: Why Your Car Needs It After Repairs

ADAS Calibration Laws by State: What the Record Actually Shows

Adjuster Scorecards and the Licence That Is Personally Yours