Projected Sold Adjustment: How to Challenge It

Key takeaways

Mitchell reports call it a Projected Sold Adjustment; Audatex Autosource reports call it a typical negotiation adjustment. Both cut each comparable’s advertised price before averaging.
In the court records reviewed here, the cuts ran about 5% of each comparable’s price (Clippinger) and 6.7% of base market value on average (Drummond).
Class actions over these adjustments have mostly failed on appeal, so argue your own numbers and your state’s rules.
Washington allows the settlement itself to be reduced only for prior unrepaired damage and salvage; comparable adjustments must be itemized and limited to options, mileage and condition. California lets insurers use a comparable’s asking price or actual sale price.
Ask in writing for removal, a recalculation and the data behind each amount, and attach local dealer listings.

Many total-loss valuation reports lower the price of every comparable car before averaging them into your car's value. Both the Mitchell and the Audatex line rest on the same assumption: that a buyer would have talked the dealer down from the advertised price. Because your value is built from those comparables, the deduction comes straight out of your payment. This guide explains how each one works, what courts and state rules say, and how to challenge it in writing.

What the projected sold adjustment is

Mitchell WorkCenter Total Loss reports, which Progressive used in the PSA cases below, print a Projected Sold Adjustment (PSA) on each comparable. A 2021 class-action complaint filed in New York shows lines such as −$707 and −$342. The report defines the term only on its last page, as an adjustment that reflects consumer purchasing behavior: negotiating a price different from the listed price.

Court records and trade press add these details:

The PSA is applied only to listed comparables that have not sold, and not to cars from "no-haggle" or "one-price" dealers. In Drummond v. Progressive (3d Cir. 2025), the court described PSAs as cutting base market value by 6.7% on average.
Press coverage of a 2025 Seventh Circuit ruling reports that J.D. Power calculates the PSA.
In Pennsylvania the report can be a "dual source" report that averages a Mitchell value (comparable list prices less PSAs) with a J.D. Power guide value. There the PSA affects only the Mitchell half.

The typical negotiation adjustment (Audatex Autosource)

Autosource reports cut each comparable's advertised price by a "typical negotiation" amount. In Clippinger v. State Farm (6th Cir. en banc 2026), the report listed four comparable minivans advertised at $15,800 to $18,803. Each was reduced by $790 to $940, about 5%, before mileage and feature adjustments, and the results were averaged to $14,490. The opinion describes the cut as a regularly adjusted percentage. An expert said it is not applied to actual sale prices or no-haggle dealer ads, though some evidence suggested it sometimes was applied to no-haggle dealers.

CCC reports and the Take Price

Trade press reports that CCC ONE does not apply a projected sold adjustment. For "Inspected Inventory" comparables, though, CCC may start from the dealer's lower "Take Price", and its sample report notes that a lower price may be obtainable through negotiation. That works like a negotiation discount and can be challenged the same way.

Go by the report, not the insurer's name: the same insurer can use different vendors in different states.

How it lowers your payment

Repairer Driven News summarized the Mitchell sequence described in the 2025 appeals rulings:

A PSA is taken off each eligible comparable's list price.
Mileage, trim and equipment adjustments follow.
The adjusted comparables are averaged into a base value.
Adjustments for your car's condition, prior damage, refurbishment and aftermarket parts are applied.
Taxes, fees and the deductible come last.

Because the deduction is taken before the average, the average deduction passes through to the base value. Where your state requires sales tax on the settlement, the tax on that amount is lost too; the total loss sales tax by state page shows which states do.

A worked example

A made-up report with four dealer comparables. Other adjustments are left out because, with a straight average, they do not change this arithmetic.

Comparable	Listed price	Projected Sold Adjustment	Price used
Comparable 1	$21,900	−$620	$21,280
Comparable 2	$22,400	−$705	$21,695
Comparable 3	$23,100	−$590	$22,510
Comparable 4	$23,800	−$885	$22,915
Average	$22,800	−$700	$22,100

Removing the PSAs would raise the base value by $700, or $749 once a 7% sales tax on that amount is included. Your report prints the real amounts for each comparable.

What the courts have said

Most of the litigation has been class actions, with mixed results.

Class actions have mostly failed on appeal. In 2025, federal appeals courts in the Third, Fourth, Seventh and Ninth Circuits refused class treatment for PSA claims. In April 2026 the full Sixth Circuit, 10–7, reversed class certification in Clippinger, after a panel had affirmed it. Insurance Business reported that this made it the sixth federal appeals court to block class certification in total-loss valuation cases.
Some owners have won. The Clippinger dissent describes a 2025 Arkansas federal jury verdict for a class challenging the same Autosource adjustment (Chadwick, E.D. Ark.).
Washington is different. In Jama v. State Farm (2024), the Ninth Circuit treated Washington's regulations as prohibiting negotiation deductions, and the damages at issue equaled the amount of the deduction.
Appraisal can move the number. In Clippinger, an appraisal panel later valued the owner's van about $4,000 above the Autosource-based offer. One case does not predict yours.

The class rulings were about trying many owners' claims together. For your own claim, argue that the deduction is unsupported for your car, not that it is illegal everywhere, and cite your state's rule if it has one.

What state rules say

Most state rules do not name these adjustments. A few speak to them directly, and many require every deduction to be itemized and explained. Look up your state in our state guides.

State	What the rule says	Citation
Washington	A total-loss settlement may be reduced only for prior unrepaired damage and, if you keep the car, salvage. Every addition and deduction must be explained in dollars, and the report must show each comparable's asking and sold price.	WAC 284-30-391, -392
California	The insurer may use a comparable's asking price or actual sale price. Every adjustment must be discernible, measurable, itemized, specified in dollars and documented.	10 CCR 2695.8(b)(2)
Alabama, Kansas	Deductions must be measurable, discernible, itemized and specified in dollars, and fully explained to you.	Ala. Admin. Code r. 482-1-125-.08; K.A.R. 40-1-34
New Jersey	You must be treated as a retail consumer, and you get a written, itemized valuation showing every deduction.	N.J.A.C. 11:3-10.4
Florida, Connecticut, New York	You can get the valuation documents or a detailed copy of the insurer's calculation.	Fla. Stat. 626.9743(5); Conn. Gen. Stat. 38a-353(b); 11 NYCRR 216.7(c)
Texas	We found no regulation on how total-loss values are calculated. The Department of Insurance tells owners to negotiate with written dealer quotes or ads, and to ask which source the insurer used.	TDI consumer tip

Washington's total-loss rules were amended effective October 18, 2026. Claims that arose before then may fall under the earlier text, which is the version Jama addressed. See Washington total loss laws and California total loss laws for the details.

Several states also let you reopen the claim if you cannot buy a comparable car for the amount paid: 35 days in California, New York and Washington, and 30 days in New Jersey, Illinois and Kansas. The start date differs by state. Send written notice before the deadline and attach the listings you found.

How to challenge it in your letter

Get the complete report. You need every comparable with its source, date, price and adjustments. If you only have a summary, ask for the full report in writing.
Add up the deductions. Total the PSA or typical negotiation amounts and divide by the number of comparables used in the value. That is roughly what the deduction cost you before tax.
Check each seller. If a comparable came from a one-price or no-haggle dealer, or is an actual sale rather than a listing, the vendors' own approach as described in court says no negotiation deduction should apply. Print the dealer's pricing policy.
Collect local evidence. Find current dealer listings for cars like yours near you, with links, VINs, mileage and prices. Written dealer quotes help show what buyers actually pay.
Make a specific request. Ask the insurer to remove the adjustment from every comparable, recalculate the base value, tax and settlement, and send you the data and percentage behind each amount.
Keep it in writing. Note any reopen deadline and keep copies of everything.

Sample wording you can adapt:

The valuation lowers each comparable's price by a Projected Sold Adjustment, averaging $____ per comparable. Actual cash value is what it would cost me to buy a comparable vehicle in my market. The adjustment is a projection, not an observed sale price, and the report gives no data supporting the specific amounts. Please remove it from every comparable, recalculate the base value, sales tax and settlement, and send me the data and percentage used for each adjustment.

In Washington you can add: "WAC 284-30-391 allows a total-loss settlement to be reduced only for prior unrepaired damage and, if I keep the vehicle, salvage. A negotiation deduction is neither." In California: "10 CCR 2695.8(b)(2) allows a comparable's asking price or actual sale price. A projected price is neither."

Keep the tone factual: show your math and attach the evidence. The guide to disputing a total loss valuation covers the rest of the letter. Our free total-loss check totals the adjustments you enter from your report and shows the average deduction in dollars.

If the insurer will not remove it

Ask in writing which policy provision or rule allows the deduction.
Read your policy's appraisal clause, if it has one, including who pays the appraisers and the umpire.
File a complaint with your state's Department of Insurance. Some departments, such as Texas's, say they cannot set damage amounts.

When to get a professional

A PSA dispute often suits self-help: the issue is narrow and the numbers are printed on the report. Consider paying for help when:

The gap is large or the insurer stops responding. A licensed attorney in your state can explain remedies such as Washington's Insurance Fair Conduct Act (RCW 48.30.015) for first-party claimants.
You are going to appraisal. An independent appraiser who knows your local market prepares your side. In Washington the insurer must tell its own appraiser about the state's total-loss rules.
You received a class-action notice that covers your claim. Read it closely. A lawyer can explain how it affects your own dispute.
A deadline is close. That includes a reopen window, any time limit in your policy and your state's statute of limitations (for property damage, 3 years in Washington and 2 in Texas).

We are self-help software, not a law firm, public adjuster or appraiser. We cannot tell you whether a deduction is lawful in your case, and we cannot promise any result.

Total loss rules in your state

Thresholds, tax rules and deadlines differ by state. Compare every state on the total loss threshold by state, total loss sales tax by state and total loss claim deadlines by state pages, or start with one of the ten most populous states:

Questions

What is a projected sold adjustment?

A deduction printed on Mitchell total-loss reports. It lowers each comparable car’s advertised price to the price a buyer is projected to pay after negotiating, before the comparables are averaged into your car’s value. Court records describe it as skipped for no-haggle dealers, and Drummond v. Progressive (3d Cir. 2025) described it as cutting base market value by 6.7% on average. Audatex Autosource reports make a similar typical negotiation adjustment.

Is the projected sold adjustment illegal?

There is no single national rule. Washington allows the settlement itself to be reduced only for prior unrepaired damage and salvage; comparable adjustments must be itemized and limited to options, mileage and condition. The Ninth Circuit in Jama treated Washington’s rules as prohibiting negotiation deductions. Elsewhere, the stronger argument is usually that the deduction is unsupported for your car.

How large is the deduction usually?

Check your own report, which prints the amount for each comparable. In court records, Drummond described a 6.7% average reduction in base market value, the Clippinger report showed cuts of about 5%, and a 2021 New York complaint showed $342 to $927 per comparable.

Will the insurer remove it if I ask?

There is no guarantee. A specific, documented request that shows your math and cites your state’s rule gives the adjuster something concrete to answer. If the insurer refuses, appraisal and a Department of Insurance complaint remain options.

What if a comparable came from a no-haggle dealer?

In Drummond, Mitchell was described as not applying the PSA to no-haggle or one-price dealers. In Clippinger, some evidence suggested Autosource sometimes applied its adjustment to them anyway. Show the dealer’s pricing policy and ask that the deduction be removed for that comparable.

Sources

General information, not legal advice. Rules differ by state and change over time. How we research and check our numbers is on the methodology page.