The trend continues for courts to interpret the scope of appraisal to include the determination of causation. The Iowa Court of Appeals joins the list of courts stating that the appraisal panel should consider causation in determining the amount of loss. In North Glenn Homeowners Association. v. State Farm Fire & Casualty Company,1 the Court concluded:
[T]he appraiser must consider what damage was caused by hail, and what damage was not, or damage with which they are unconcerned, such as normal wear and tear. We are convinced to hold otherwise would improperly limit the appraisal process to situations where the parties agree on all matters except the final dollar figures.
While many courts still refuse to allow the determination of causation in appraisal, more and more courts are finding that this approach limits and frustrates the purpose of the appraisal provision.
1 North Glenn Homeowners Ass’n. v. State Farm Fire & Cas., 854 N.W.2d 67 (Iowa Ct. App. 2014).