Progressive Total Loss Settlements: Where Each State Actually Stands
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Brown v. Progressive settlement, Georgia's $43 million case, is closed — but Colorado is now open: a $15.24 million settlement in Curran v. Progressive takes claims until February 5, 2027. Georgia, New York, Alabama and Arkansas settled for a combined $135 million over the same practice, and every one of those deadlines has passed. North Carolina and Ohio have certified classes with no settlement; Illinois was refused certification.
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Reviewed by Leonard Goldberg, Editor · Last updated
The Practice at the Centre of Every Case
All of these cases allege the same thing. When Progressive declares a vehicle a total loss, it pays actual cash value. To determine that value it used valuation software — Mitchell WorkCenter / Autosource — which applied a "Projected Sold Adjustment" to the comparable vehicles used in the calculation.
Plaintiffs argued that this adjustment had no statistically defensible basis and systematically pushed valuations downward, so policyholders were paid less than the policy promised. Progressive settled in four states without admitting wrongdoing, which is standard and does not by itself establish that the practice was improper.
Case Details
Georgia: Brown v. Progressive Mountain / Bost v. Progressive Premier, consolidated No. 3:21-cv-00175-TCB (N.D. Ga., Judge Batten). New York: Volino v. Progressive Casualty Ins. Co., No. 1:21-cv-06243 (S.D.N.Y.). Alabama: Reynolds v. Progressive Direct Ins. Co., No. 5:22-cv-00503-LCB (N.D. Ala.). Arkansas: Knight v. Progressive Northwestern Ins. Co. Colorado: Curran v. Progressive Direct Ins. Co., No. 1:22-cv-00878-SKC-TPO (D. Colo., Judge S. Kato Crews; the class notice prints the suffix as SKC-TKO).
Colorado Is Open — Every Other Settled State Is Closed
Georgia — $43 million. Class period October 11, 2015 to February 18, 2025. No claim form was required; payment is automatic, averaging about $173. The objection deadline passed April 30, 2025.
New York — $48 million. Class period July 28, 2015 to August 20, 2024. Opt-out deadline was November 19, 2024. A third payment wave went out on May 1, 2026.
Alabama — $30.75 million. Class period April 20, 2016 to May 21, 2025. Claim deadline was October 15, 2025.
Arkansas — $13.21 million. Class period August 4, 2017 to May 19, 2025. Claim deadline was October 25, 2025; payments issued April 26, 2026.
If you were in one of the four older classes and did nothing, Georgia and New York paid automatically. Alabama and Arkansas required a claim, and those windows are shut.
Don't miss the claim deadline
Claims are due by February 5, 2027. We'll email you 7 days and 1 day before the deadline.
Where Something Might Still Happen
Colorado moved from certified to settled. The Colorado class had already been certified; on May 27, 2026 the court denied Progressive's motion to decertify it. The parties signed a settlement on June 29, 2026 and filed for preliminary approval on July 1. The class period in the court-approved notice ends on July 8, 2026 — under the parties' proposed order, the date preliminary approval was entered.
According to Progressive's own quarterly report to the SEC covering the period ended June 30, 2026, classes have also been certified or preliminarily certified in North Carolina and Ohio. Certification is not a settlement: in those two states there is no fund, no administrator, no deadline and no amount. It does mean the cases are advancing as class actions rather than individual suits — Colorado shows that this can come before a settlement, but it is not a promise of one.
Illinois went the other way. On April 15, 2026 a federal judge denied class certification against Progressive Universal Insurance Company, finding commonality and predominance were not satisfied because the named plaintiffs had chosen Progressive for reasons unrelated to the valuation method. That case continues as an individual claim.
Additional putative class actions are pending in further states according to the same SEC filing, which does not name them.
What These Actually Paid
Colorado pays by formula. The settlement treats the Projected Sold Adjustment as a fixed share of your car's actual cash value in Progressive's records — 2.75% for Progressive Direct policies, 2.25% for Progressive Preferred — and pays 68% of that. In effect that is about 1.87% or 1.53% of the actual cash value: roughly $374 or $306 on a $20,000 car (our arithmetic). The $15,240,887 is the parties' estimate of what is available to be claimed. Progressive agreed to settle only on a claims-made basis, so it pays approved claims, and money from uncashed checks goes back to Progressive. Class counsel's fees of up to $4,572,199 and costs of up to $200,000 are paid separately and do not reduce class payments.
These are not life-changing individual amounts, and that is typical of insurance underpayment class actions: the per-person shortfall is modest, the class is very large, and the aggregate is what makes the case worth bringing. If you are still inside a certified class in North Carolina or Ohio, this is the order of magnitude to expect if a settlement eventually happens.
Timeline
- 1
November 19, 2024 — New York opt-out closes
The $48 million New York settlement moves toward distribution.
- 2
April 30, 2025 — Georgia objection deadline
The $43 million Georgia settlement is finalised. No claim form is needed; payments average about $173 and go out automatically.
- 3
June 2025 — Arkansas jury trial, then settlement
After a five-day trial the parties settle for $13.21 million rather than await a verdict.
- 4
October 2025 — Alabama and Arkansas claim deadlines
October 15 for Alabama, October 25 for Arkansas. These were the last Progressive total-loss windows requiring action from class members.
- 5
April 15, 2026 — Illinois certification denied
A federal judge declines to certify a class against Progressive Universal, and the case proceeds as an individual claim.
- 6
May 27 – July 1, 2026 — Colorado goes from trial track to settlement
The court refuses to decertify the Colorado class on May 27. The parties sign a settlement on June 29 and file for preliminary approval on July 1: about $15.24 million available, 68% of the Projected Sold Adjustment.
- 7
June 30, 2026 — North Carolina and Ohio still certified, not settled
Progressive's quarterly SEC filing lists certified or preliminarily certified classes in Colorado, North Carolina and Ohio. Colorado has since settled; North Carolina and Ohio have no settlement.
- 8
November 5, 2026 to February 5, 2027 — Colorado deadlines
Opt-out and objection letters must be postmarked by November 5, 2026; the fairness hearing is January 6, 2027 at 10:00 a.m. in Denver; claim forms are due February 5, 2027 (online by 11:59 p.m. ET).
Three Things That Mislead People Here
Insurance class action coverage ages badly, and old articles keep surfacing as if they were current.
Any site offering a Progressive total loss claim form outside Colorado
The only live claim process is Colorado's, run by the court-appointed administrator Verita at COTotalLossClaim.com (1-888-808-1463). Georgia, New York, Alabama and Arkansas are closed, and North Carolina and Ohio have no settlement to claim from. Filing a claim never costs money.
Confusing certification with settlement
"Class certified in Ohio" means the case can proceed collectively. It does not mean money exists, and it carries no deadline you could miss.
Assuming your state settled because another one did
This litigation is state by state, with different class periods and outcomes — Georgia paid automatically, Alabama required a claim, Illinois was refused certification entirely.
Frequently Asked Questions
Can I still claim from a Progressive total loss settlement?
Only in Colorado. If Progressive Direct or Progressive Preferred totaled your car on a Colorado policy and the valuation applied a Projected Sold Adjustment, you can file in Curran v. Progressive until February 5, 2027 at COTotalLossClaim.com. Georgia, New York, Alabama and Arkansas have all closed: Georgia and New York paid automatically without a claim form; Alabama's deadline was October 15, 2025 and Arkansas's was October 25, 2025.
I was in the Georgia or New York class and never got anything.
Both paid automatically rather than by claim, so payment went to the address on file. If you moved, the administrator may hold an undeliverable payment — contact the administrator for your state's settlement rather than a third-party site.
What is a Projected Sold Adjustment?
A downward adjustment the valuation software applied to comparable vehicles when computing actual cash value, on the theory that listed prices are negotiated down before sale. Plaintiffs argued it lacked statistical support and systematically reduced payouts.
My car was totalled in Colorado, North Carolina or Ohio.
Colorado now has a settlement. If your total-loss claim falls in its class periods — Progressive Direct from April 12, 2019, Progressive Preferred from December 19, 2021, both through July 8, 2026 — you should have received a postcard or email with a Claimant ID and PIN; if not, the administrator can send a claim form (1-888-808-1463). North Carolina and Ohio are certified or preliminarily certified, which means those cases are proceeding collectively — but there is no settlement, no fund and no deadline there. If one is reached, class members are notified; there is nothing to file in the meantime.
Does this mean Progressive did something illegal?
The settlements were made without admissions of wrongdoing, which is standard. Illinois declined to certify a class at all. What can be said factually is that Progressive resolved claims about this valuation practice in four states for a combined $135 million.
Do other insurers do the same thing?
Similar actual-cash-value litigation has been brought against other carriers, including State Farm and GEICO, over comparable valuation adjustments and unpaid fees. The specific software and adjustment names differ from case to case.
How would I know if a new settlement opens?
Class members of a certified class are notified directly by the court-appointed administrator using the insurer's own records — you do not need to register anywhere in advance, and any site asking you to sign up now to "reserve" a claim is not part of that process.
How much will the Colorado settlement pay me?
68% of the PSA Impact Amount, which the settlement fixes at 2.75% of your vehicle's actual cash value for Progressive Direct and 2.25% for Progressive Preferred, using the value in Progressive's own records. That is about 1.87% or 1.53% of the car's value — around $374 or $306 on a $20,000 vehicle, by our arithmetic. Payment comes by check unless you choose an electronic method on the claim form, and only after final approval: Progressive funds approved claims within 30 days of the later of the effective date or the approved-claims list, and the administrator pays within 60 days after that. Checks are valid for 180 days.
Separate from this case: were you injured in the last 2 years?
Class-action payouts are fixed amounts through an administrator. A personal injury claim is a different case — and often worth far more. Free estimate, no obligation.