In the case of Sproull v. State Farm, an Illinois appeals court recently ruled that an insurer could not depreciate labor as a component of replacement cost. The court analyzed whether labor, as a component of replacement cost, may be depreciated when calculating actual cash value where Illinois Department of Insurance regulations describe actual cash value as replacement cost of property at time of loss, less depreciation, while the insurance policy is silent as to the definition of that term or the manner in which replacement cost is depreciated. The ruling is in relation to the Sproull’s filing of a putative class action complaint in Madison County, Illinois, on Sept. 23, 2016, alleging that State Farm breached its contractual obligations to the plaintiff and to similarly situated policyholders by improperly and deceptively depreciating the cost of intangible components of replacement cost, such as labor.