Bartee v. Progressive Advanced Insurance Company

CourtDistrict Court, E.D. Missouri
DecidedSeptember 30, 2025
Docket4:22-cv-00342
StatusUnknown

This text of Bartee v. Progressive Advanced Insurance Company (Bartee v. Progressive Advanced Insurance Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bartee v. Progressive Advanced Insurance Company, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

LILLIAN BARTEE, et al., individually and on ) behalf of all others similarly situated, ) ) Plaintiffs, ) ) vs. ) Case No. 4:22-cv-00342-MTS ) PROGRESSIVE ADVANCED INSURANCE ) COMPANY, et al., ) ) Defendants. )

MEMORANDUM AND ORDER This matter is one of many filed by plaintiff-insureds across the country to challenge a specific price-negotiation adjustment that their insurers applied when making insurance claim settlement payments. As in those cases, Plaintiff Lillian Bartee and Plaintiff Lisa Bledsoe assert that their claims are appropriate for class treatment and have filed a Motion for Class Certification. Doc. [60]. Defendant Progressive Advanced Insurance Company (“Progressive Advanced”) and Defendant Progressive Casualty Insurance Company (“Progressive Casualty”) oppose the Motion, and they also move to exclude the testimony of several of Plaintiffs’ retained experts, specifically: Kirk Felix, Jeffrey Martin, and Jason Merritt. Docs. [85], [86], and [87]. For the reasons that follow, the Court will deny each Motion at this time. I. Background Plaintiff Bartee was involved in an automobile accident in late spring of 2018. She was insured under a policy issued by Progressive Advanced, and she made a claim for property damage pursuant to that policy. Likewise, Plaintiff Bledsoe crashed her vehicle in September of 2021, she was a party to an insurance policy issued by Progressive Casualty, and she submitted a corresponding claim. Defendants determined that both of Plaintiffs’ vehicles were a total loss following their accidents. To settle Plaintiffs’ respective claims, Defendants used valuation reports prepared by their third-party vendor, Mitchell International, Inc. (“Mitchell”), to calculate the actual cash value (“ACV”) of Plaintiffs’ vehicles. Accordingly, Progressive Advantage paid Plaintiff Bartee $8,196.13 to resolve the matter, Doc. [39-2] at 1; Doc. [76-20] at 2, and Progressive

Casualty likewise paid Plaintiff Bledsoe $2,976.86, Doc. [39-3]. Plaintiffs assert that Defendants impermissibly decreased these amounts when Defendants applied Projected Sold Adjustments (“PSAs”) during the calculation process. To arrive at valuations like these, Mitchell uses its WorkCenter Total-Loss (“WCTL”) database to generate a report for each loss vehicle. Each report aggregates data from comparable vehicles within a certain geographical region. Some of those comparator vehicles have sold for a certain price, and other comparators are merely listed for sale at a certain price. If a comparable vehicle has already sold, Mitchell uses the vehicle’s sold price as the starting point for its calculations. Michell applies adjustments to the sold price based on “verified differences between

each respective comparable vehicle and the insured vehicle in mileage, equipment, and condition.” Doc. [61] at 9. The adjusted values of each comparable vehicle are averaged to establish a “base value” for the insured-claimant’s loss vehicle. See, e.g., Doc. [39-2] at 3. For comparable vehicles that have not yet sold, however, Mitchell applies one additional threshold adjustment. Rather than use the unsold vehicles’ advertised or “list” price as the starting point for its calculations, Mitchell applies the PSA to “reflect customer purchasing behavior” as those customers negotiate “a different price than the list price.” Doc. [39-2] at 10.1 Evidence in the record suggests that the PSA is always a negative adjustment. Doc. [62-4] at 63. For example, as described in the Mitchell

1 PSAs are not applied to unsold comparator vehicles that are listed for sale by single-price or no-haggle dealers. See Doc. [62-4] at 97. Report prepared for Plaintiff Bartee, the PSA reduced the list price of six comparable, unsold vehicles by approximately $802 on average. Doc. [39-2] at 6–9 (showing list-price reductions of $878, $744, $811, $793, $856, and $731). For both types of comparator vehicles, Mitchell applies further market adjustments related to the condition and other aspects of insured-claimant’s loss vehicle to arrive at “the [loss] vehicle’s adjusted market value.” Doc. [61] at 13. “Finally, any

taxes, fees, and deductible are automatically calculated and applied, which becomes the ultimate claim payment amount.” Id.; see also Doc. [61-5] at 148–49. From Plaintiffs’ perspective, much of the methodology Mitchell uses to calculate ACV is unobjectionable. Doc. [61] at 11. But Plaintiffs do object to the PSA and argue that, by applying it, Defendants systematically breach the contractual obligations set forth in their insurance policies. Those policies uniformly provide that, when an insured suffers a covered loss, Defendants will pay, as applicable, “the [ACV] of the stolen or damaged property at the time of the loss reduced by the applicable deductible.” Doc. [61-3] at 29. Further, ACV “is determined by the market value, age, and condition of the vehicle at the time the loss occurs.” Doc [61-3] at 30. According

to Plaintiffs, whenever Defendants purport to pay ACV of a loss vehicle after applying a PSA during the evaluation process, Defendants do not pay ACV “as determined by the market value” as the policy requires; instead, Defendants calculate an artificially lower value and pay a lower ACV as a result. Doc. [61] at 23. Plaintiffs raise two key issues with respect to the PSA. First, Plaintiffs contend that the PSA is based on a false premise and does not resemble market realities applicable to buying and selling used cars. According to Plaintiffs, Defendants apply the PSA based on an incorrect assumption that car dealers list their used-car inventory at inflated prices, which they ultimately expect to lower when their customers seek to negotiate a lower price. Doc. [61] at 13. Plaintiffs’ industry expert, Kirk Felix, opines that price negotiation or haggling at car dealerships may have been commonplace years ago, but the advent of internet advertising as well as real-time pricing and car comparison tools have caused dealers to price their cars to market. See Doc. [61-8] at 4– 5. Plaintiffs argue that the PSA is therefore spurious because car dealers no longer mark up their car prices and, for that reason, are unwilling to accept a lower price that a customer might offer.

Id. at 4. Defendants counter that vehicles regularly sell for less than their list price, Doc. [76] at 9–10, and therefore the PSA does reflect consumer purchasing behavior. Second, Plaintiffs argue that Defendants and their vendors have impermissibly manipulated the data underlying the PSA such that the negative adjustment is artificially inflated. Doc. [61] at 15; Doc. [62-5] at 5. They assert that, until July 2021, every transaction in which a used vehicle sold at or above its advertised price was excluded from the data used to calculate the PSA. Doc. [62-5] at 4. And to date, any transaction in which a used car sold for more than the list price is still excluded. Id. at 4–5. The result, Plaintiffs contend, is an inflated PSA that results in a greater reduction in list price than would otherwise occur if the excluded transaction data were

used. See id. at 5. Defendants reply that, as their retained experts demonstrate, the PSA accurately estimates the difference between a used vehicle’s list price and the price for which it ultimately sells. Doc. [76] at 12; Doc. [80] at 12. Accordingly, from Defendants’ perspective, any data that is excluded from the calculation helps ensure that an accurate PSA is applied. To summarize, Plaintiffs assert that the PSA is a categorically impermissible deduction that breaches the terms of their insurance policies.2 Doc. [61] at 23 (“The central question is

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Bartee v. Progressive Advanced Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bartee-v-progressive-advanced-insurance-company-moed-2025.