RMP Properties of Valdosta, LLC v. Houston Specialty Insurance Company 1 is a reminder that appraisal is often won or lost before the first appraiser ever swings a ladder onto the property. The case involved a Shreveport motel damaged by a February 2024 wind and hail storm. Houston Specialty’s initial adjustment placed the damage below the deductible. The policyholder’s public adjuster estimated the damage much higher. Houston Specialty then relied on engineering and building consultant opinions to keep the covered amount below the deductible and pay nothing.
The policyholder, frustrated with the claim handling and lack of payment, invoked appraisal. Later, after suit was filed and the policyholder believed the appraisal was being limited too narrowly to roof damage, it attempted to withdraw from the appraisal.
Houston Specialty moved to compel appraisal and appoint an umpire. The insurer’s argument was that the policy said that once appraisal is demanded, each side “will” select an appraiser, the appraisers “will” select an umpire, and the appraisal process must continue. Houston Specialty argued that RMP rang the appraisal bell and could not later pretend nobody heard it.
RMP contended that this was not merely a fight over dollars. It was a fight over coverage, causation, scope, and claims handling. The policyholder argued that appraisal was not designed to decide whether damage was caused by hail, faulty drainage, wind-driven rain, mechanical condensation, or some other cause. RMP also argued that if the appraisal panel considered only the insurer’s narrow version of the loss, any award would be incomplete and potentially useless.
That is the real danger in these appraisal fights. Insurers often say, “Let the appraisers decide the amount of loss,” while simultaneously trying to cabin the appraisal to only those items the insurer has already admitted are covered. If that happens, appraisal can become less a neutral valuation process and more a procedural ratification of the insurer’s adjustment. A policyholder that demands appraisal must be very careful to define the scope of what is being appraised. Otherwise, the battle may be lost in the framing. I have cautioned public adjusters about advising a party to demand appraisal when coverage issues such as these exist because many would consider that as providing legal advice to a policyholder.
The court granted Houston Specialty’s motion to compel appraisal. Magistrate Judge Mark Hornsby found that RMP’s appraisal demand was timely because it came soon after it became apparent that the parties’ adjusters and estimators could not agree. The court also rejected RMP’s argument that Houston Specialty waived appraisal by waiting too long to seek an umpire. The judge placed much of that delay at RMP’s feet because RMP had withdrawn from the appraisal process and filed suit.
The most important part of the ruling is the court’s treatment of causation. The court held that even where exclusions or causation disputes exist, appraisers in Louisiana may still make loss assessments and causation determinations. But the court added an important warning that causation determinations in an appraisal award may still be challenged by the parties.
That sounds practical, but it is also where the waters get muddy. Appraisal is supposed to be faster and less expensive than litigation. But if the appraisers make causation decisions that are later challenged in court, the parties may simply be buying a ticket to two fights instead of one. To me, that is not efficiency and costs the policyholder time and money fighting twice to get policy benefits.
The court did get one point exactly right. Houston Specialty asked the court to appoint an umpire immediately. The court refused to skip the policy language. The policy required the two appraisers to first try to select an umpire. Only if they cannot agree does the court step in. That was a sound ruling. Courts should enforce appraisal clauses as written, not as one party wishes they had been written after the dispute becomes inconvenient.
My view is that Houston Specialty had the better procedural argument, but RMP had the better warning. Once a policyholder invokes appraisal under mandatory policy language, courts are likely to force the process forward. But courts should be careful that appraisal does not become a way to shrink the claim before the valuation ever begins. The promise of appraisal is a fair and independent determination of the amount of loss. It should never become a game wearing down the policyholder.
Thought For The Day
“Louisiana is a fresh-air mental asylum.”
— James Lee Burke, Pegasus Descending
1 RMP Properties of Valdosta v. Houston Specialty Ins. Co., 5:26-cv-00962, 2026 WL 1864342 (W.D. La. June 29, 2026). See Houston Specialty Motion to Compel Appraisal and RMP Opposition to Motion to Compel.