GEICO Sent Four Valuations of One Tesla. The Lowest One Says GEICO Directed the Comps.

GEICO emailed my family a package at 4:27 on the afternoon of October 21. The title on it: “Claim Documents”. Inside was a cover sheet and four CCC ONE Market Valuation Reports. One car. Three different bottom lines. And not one word about which of them is the offer.

The car’s a 2017 Tesla Model X 100D. Two of the four reports value a 90D. And the lowest of the four carries this line from the company that makes the software:

INSURER DIRECTED CCC ON THE CRITERIA AND/OR VEHICLES TO USE AS COMPARABLE VEHICLES FOR THIS VALUATION.

That’s not me talking. That’s the software.

This one’s personal. It’s my family’s car, and I’m the one on the loan, so every dollar GEICO shaves off comes straight out of my pocket. The claim’s still open. Nothing’s settled, and nobody knows yet how it ends. But if you’ve had a car totaled in Minnesota lately, there’s a decent chance one of these reports is sitting in your inbox right now, and nobody told you to flip to the notes page.

What we’re fighting about

Here’s the car. A 2017 Model X 100D with 117,663 miles. Six seats, with the second-row captain’s chairs. Full Self-Driving that’s owned with the car, not a subscription; the Tesla app lists “Full Self-Driving (Supervised)” under active upgrades as “Included”. White perforated leather, which Tesla’s own collision estimate prices as an “LT Seat assy leather, w/perforated white”. A $500 collision deductible. The loss was October 10.

We didn’t sit around waiting for GEICO’s number. On October 16 at 3:57 p.m. I sent the adjuster our valuation package: thirteen six-seat 2017 100Ds, every one confirmed by VIN, one of them a direct match. That one’s a six-seat 100D with owned Full Self-Driving, listed by a private seller in Haymarket, Virginia, at $27,900 with 124,909 miles. That’s 7,246 more miles than ours. Our number: $32,000 in actual cash value.

That afternoon the adjuster called with $25,000. On the phone. Nothing in writing.

Then the paperwork showed up. Four reports and a cover sheet.

Four reports, three prices, one VIN

Here’s the lineup, in order, by each report’s own “Last Updated” stamp:

Start with the first two rows. Same VIN. Two minutes apart. At 2:46 the car’s a 90D. At 2:48 it’s a “100D Long Range”. Nothing happened to the VIN in those two minutes. Something sure happened to the trim.

The $24,693.89 report is the one that lines up with the $25,000 phone call. So the closest thing in writing to the number I was quoted on October 16 values a car my family doesn’t own.

Then the 8:44 report, the lowest of the bunch. Same wrong trim, last updated a day later. That one’s comparables aren’t in Illinois and Ohio. They’re in Turlock, California; Pelham, Alabama; Pompano Beach, Florida; and Delray Beach, Florida. Lovely places. Not exactly down the road. The total dropped $3,054.49.

The reports can’t even agree on when the claim came in. “Claim Reported” says October 14 on one, October 16 on another, and October 20 on the two 100D reports. Four reports, three dates. If my office kept a file like that, I’d never hear the end of it.

Page 1 and page 12 disagree about whose opinion this is

You’d figure a disclosure like this would be buried. Some of it’s right on the front. Page 1 of all four says:

Prepared for GEICO GENERAL INSURANCE COMPANY

And:

The CCC ONE® Market Valuation Report reflects CCC Intelligent Solutions Inc.’s opinion as to the value of the loss vehicle, based on information provided to CCC by GEICO GENERAL INSURANCE COMPANY.

So page 1 tells you two things. This is CCC’s opinion, and CCC based it on what GEICO told it. The same page says the lines marked with an asterisk “have been determined by GEICO GENERAL INSURANCE COMPANY and have been added here for convenience.” On these reports, that’s the deductible, and on the two 90D reports the fees. That part’s routine. Nobody expects the software to pick your deductible.

The methodology page spells out what “information provided” means: “GEICO GENERAL INSURANCE COMPANY has provided CCC with the zip code where the loss vehicle is garaged, loss vehicle VIN, mileage, equipment, as well as loss vehicle condition”. Read that list again. The equipment and the condition come from GEICO. Hang on to that.

Now flip to the Valuation Notes. On the 8:44 a.m. report that’s page 12, and here’s the entry, start to finish:

10/16/2026 11:52 - INSURER DIRECTED CCC ON THE CRITERIA AND/OR VEHICLES TO USE AS COMPARABLE VEHICLES FOR THIS VALUATION. THE VALUATION DOES NOT NECESSARILY REFLECT CCC’S OPINION AS TO THE MARKET VALUE OF THE LOSS VEHICLE.

Page 1 says the report reflects CCC’s opinion. Page 12 says, well, not necessarily. Same report. I had to read that twice. Only the 8:44 report carries that entry. The other three don’t.

And every one of the four notes pages signs off the same way:

This Market Valuation Report has been prepared exclusively for use by GEICO GENERAL INSURANCE COMPANY, and no other person or entity is entitled to or should rely upon this Market Valuation Report and/or any of its contents. CCC is one source of vehicle valuations, and there are other valuation sources available.

That’s the document GEICO sent us to explain what it’ll pay, and it tells us not to rely on it. You can’t make this stuff up. The software’s more candid than the carrier. It even tells you which law to go read: “Statutes concerning vehicle value include Minnesota Statute 72A.201.” Thanks, CCC. I’ll get there.

The clock

Here’s how the week went. The times on the reports are each report’s own clock, and the reports don’t print a time zone, so take them as stamped.

• Oct. 16, 11:52 a.m. — the “INSURER DIRECTED” entry lands on the valuation that became the 8:44 a.m. report.
• Oct. 16, 3:57 p.m. — our package goes to the adjuster. The $25,000 phone offer comes after that.
• Oct. 19, 4:15 p.m. — a note on the 8:44 report: “PVADJ CHANGE REQUESTED BY: [the adjuster]”. Same afternoon, the adjuster emails that our documentation went to “the valuation company.”
• Oct. 20, 2:46 and 2:48 p.m. — the 90D report, then the 100D report.
• Oct. 21, 8:34 a.m. — I email the adjuster about the rental car. GEICO’s position: “the 72-hour window starts once the total loss offer has been provided.”
• Oct. 21, 8:44 a.m. — the 90D report is last updated. $21,639.40.
• Oct. 21, 8:45 a.m. — another “PVADJ CHANGE”, this time on the 100D valuation. It gets reprinted at 10:54 with the same total and two extra comparables, each flagged as “added, for informational purposes, and was not used to determine the vehicle value.”
• Oct. 21, 4:27 p.m. — the package hits my family’s inbox.

Look at the top two lines. The instruction to CCC is stamped hours before our package went out. Whatever GEICO told CCC on October 16, it told CCC before it had seen a single one of our numbers.

Here’s one for GEICO’s side of the ledger. The older 90D report logs its own string of changes on October 15: “Options removed :[Cloth Seats]”, “Options added :[Leather Seats]”, “Post Valuation Adjustment entered for:”. Those edits added leather, the third row, and dual air conditioning. They were corrections, and they helped us. A post-valuation change isn’t automatically a bad one.

My October 21 email asked GEICO to pull the two 90D reports and tell us which number is the offer. The next question is what GEICO handed CCC on October 16: the criteria, the vehicle list, or both, and who supplied them. Draw your own lines between those timestamps.

What GEICO told the software about my car

GEICO feeds the software the equipment and the condition. So let’s see what it fed it.

No Autopilot. The 8:44 report says the car has no Autopilot. GEICO’s own 100D report credits the very same car with Autopilot, Enhanced Autopilot, and Full Self-Driving. And it gets better. One of the Florida comparables does have Autopilot, so CCC docked that comparable $207 under “Package” to make it look more like our car. Read that again. Our FSD car got valued down for a feature it has.

Cloth seats. The 100D reports, the ones with the right battery, say cloth seats and no leather. The 90D reports got leather swapped in back on October 15. So the right-trim report has the wrong seats, and the wrong-trim reports have the right seats. Pick one, GEICO.

Five-seat comparables for a six-seat car. Tesla tucks the seat count into the VIN. The sixth character is the restraint-system code, and Tesla’s 2017 decoder, filed with NHTSA, defines “B” as two second-row and two third-row seating positions, and “D” as three second-row positions with no third row. Our VIN has a B. Of the five comparables the 100D report actually uses, two (Denver and Tulsa) carry a D. The report’s own option grid shows the Denver car without a third row. That’s a five-seater standing in for a six-seater.

A dealer price, docked to a private-party price. Each of the three featured comparables in the 100D report takes the same flat $1,169 “Condition” haircut. The footnote says the adjustment “sets that comparable vehicle to Average Private condition”. Two lines up, the same page says “List Price is the sticker price of an inspected dealer vehicle and the advertised price for the advertised vehicle.” All three are listed by dealerships. Go ahead, walk onto one of those lots and offer the private-party number. Let me know how that goes. In fairness, CCC added $605 back to our car for condition. That’s $605 in, against $1,169 off every featured comparable.

Full Self-Driving. CCC puts FSD at $1,082 on the allowance page. When it adds the whole stack, Autopilot, Enhanced Autopilot and FSD, to a comparable that doesn’t have it, the figure is $2,164. Now look at the Haymarket car: same battery, same six seats, owned FSD, 7,246 more miles, asking $27,900. GEICO’s right-trim report puts our car at $23,128 before tax. That’s a $4,772 gap, and ours is the one with fewer miles.

The fees. The two 90D reports found $95.67 in title, registration and other fees. The two 100D reports say “Title, registration and other fees were unable to be determined for this claim.” Same car. It’s small money. But the only reports that got the battery right are the ones that lost the fees.

What does Minnesota’s total-loss statute say about all this?

CCC told me to read § 72A.201, so I did. Again. Subdivision 6(1)(b) sets the measure of a cash settlement on a total loss:

a cash settlement based upon the actual cost of purchase of a comparable automobile, including all applicable taxes, license fees, at least pro rata for the unexpired term of the replaced automobile’s license, and other fees incident to transfer of evidence of ownership, less the deductible amount as provided in the policy.

The actual cost of purchase. What it costs to go buy one. Not the private-party value of a car parked on a dealer lot. Then clause (i):

(i) the cost of a comparable automobile, adjusted for mileage, condition, and options, in the local market area of the insured, if such an automobile is available in that area; or

Now one that doesn’t help me. There’s no local market for this car. Our own package went national too. A Waukesha comparable doesn’t break the law just because Waukesha isn’t the west metro. When there’s no comparable in the local market, the statute’s next option is clause (ii):

(ii) one of two or more quotations obtained from two or more qualified sources located within the local market area when a comparable automobile is not available in the local market area. The insured shall be provided the information contained in all quotations prior to settlement; or

None of the four reports is built on local-market quotations. That leaves clause (iii):

(iii) any settlement or offer of settlement which deviates from the procedure above must be documented and justified in detail. The basis for the settlement or offer of settlement must be explained to the insured;

Documented and justified in detail. A note saying the insurer directed the criteria “and/or” the vehicles, with nothing about what that direction was, doesn’t get there. Neither does a pair of same-trim reports, last updated a day apart, one pulling comparables from 344 miles away and the other reaching out to 1,499 miles, when CCC’s own methodology page says “The zip code where the loss vehicle is garaged determines the starting point for the search” and lists “Proximity to the loss vehicle’s primary garage location” as a weighting factor. That’s CCC’s method, in CCC’s words.

Then there’s subdivision 5(1). It’s an unfair settlement practice to make an offer “which does not include an explanation of what the payment, settlement, or offer of settlement is for”. GEICO sent four reports with three totals and didn’t say which one is the offer. Meanwhile the rental clock supposedly started ticking the moment “the total loss offer has been provided.” Provided which one? Pick a number. Any number.

Fine. So can I sue GEICO under that statute?

Nope. Neither can you. Subdivision 1 hands enforcement to the Commerce commissioner. The Court of Appeals said so again on October 12, in a case against GEICO, of all companies: “But there is no private cause of action under section 72A.201.” I wrote about that decision and the “We use our numbers” tape last week, and our total-loss guide covers what the statute’s still good for.

The leverage, on your own policy, is the contract claim, and after that Minnesota’s bad-faith statute, § 604.18. Its second element asks whether the insurer “knew of the lack of a reasonable basis for denying the benefits of the insurance policy” or acted in reckless disregard of it. What an insurer knew, and when it knew it, is a fact question. Facts like a timestamped instruction to its valuation vendor.

Here’s the catch, and it’s a big one. Subdivision 4(d)(4) of § 604.18 says “provisions under chapters 59A to 79A and rules adopted under those sections are not admissible as standards of conduct.” Chapter 72A sits inside that range. So § 72A.201 can’t walk into a bad-faith proceeding as the yardstick. The documents can. And § 604.18 relief is “not available in any claim that is resolved or confirmed by arbitration or appraisal”, which is why the guide treats appraisal as a trade, not a freebie.

If one of these lands in your inbox

Before I argued about a single dollar, here’s what I’d check, in this order.

1. Page 1, “Loss Vehicle”. Does the trim match your car? Run your VIN. Two of my four flunked.
2. The Valuation Notes page. It’s near the back, right before the supplemental pages. Hunt for “INSURER DIRECTED” and for “PVADJ” entries, and write down every date.
3. The equipment pages. GEICO fills those in. Check the seats, the driver-assist packages, and the options against your window sticker or your app.
4. The comparables. Where they are, how many seats the VIN says they have, and whether a dealer car got knocked down with a “Condition” deduction to “Average Private”.
5. The fees. If the report says it couldn’t figure them out, the statute still says they’re part of the settlement.
6. Which number is the offer. Ask in writing. Get the answer in writing.

When a vendor’s own report says it doesn’t necessarily reflect the vendor’s opinion, it’s reflecting somebody’s. Whose is the next question for GEICO.

Madgett Law, LLC handles Minnesota first-party insurance disputes, including lowballed total losses and the § 604.18 motion practice that sometimes follows. We read the valuation report line by line, notes page included, and put the response in writing with the subdivision cited. If your insurer’s report doesn’t describe your car, send us a message.

Sources: GEICO General Insurance Company claim correspondence cover, Oct. 21, 2026, and four CCC ONE Market Valuation Reports prepared for GEICO General Insurance Company for the author’s family’s 2017 Tesla Model X (last updated Oct. 20, 2026, 2:46 p.m. and 2:48 p.m.; Oct. 21, 2026, 8:44 a.m. and 10:54 a.m.), at p. 1 (prepared-for line; CCC opinion “based on information provided to CCC by” GEICO; asterisked adjustments determined by GEICO; trim; claim-reported date; totals; fees note on the 100D reports), pp. 2–3 (valuation methodology; GEICO-provided inputs; search starting point; proximity weighting), pp. 9–13 (comparables, list prices, distances, VINs, package, option, mileage and condition adjustments; condition footnote; list-price definition; informational comparables), and pp. 11, 12 and 14 (valuation notes, including the Oct. 16, 2026 insurer-directed entry, PVADJ entries, Oct. 15, 2026 option changes, exclusive-use statement, and § 72A.201 reference). Tesla, Inc., 2017 Model Year VIN Decoder submitted to NHTSA (May 8, 2017), digit 6 restraint-system codes, NHTSA vPIC manufacturer information database. Tesla Collision Eden Prairie Service Estimate SV02F89CB9 (Oct. 13, 2026) (leather seat assembly). Tesla app, Upgrades › Manage › Active (Oct. 16, 2026). Minn. Stat. § 72A.201, subd. 1 (administrative enforcement by the commissioner), subd. 5(1) (offer must explain what it is for), subd. 6(1)(b), (b)(i), (b)(ii), (b)(iii) (total-loss cash settlement; local-market comparable; local-market quotations; deviation documented, justified, and explained) — Minnesota Office of the Revisor of Statutes. Minn. Stat. § 604.18, subd. 2(a)(2) (knowledge or reckless-disregard element), subd. 4(c) (unavailable after arbitration or appraisal), subd. 4(d)(4) (chapters 59A to 79A not admissible as standards of conduct) — Minnesota Office of the Revisor of Statutes. Villanueva v. GEICO Casualty Co., No. A26-0557 (Minn. Ct. App. Oct. 12, 2026) (nonprecedential), slip op. at 11, Minnesota State Law Library archive.

This article is general legal information about Minnesota law, not legal advice, and reading it does not create an attorney–client relationship. It describes an open insurance claim involving the author’s family; the claim is unresolved, and nothing here predicts how any insurer, regulator, or court would handle this claim or any other. No outcome is promised or implied.