(Minn. Aug. 21, 2007). Despite these precedents, we recently observed that Minnesota courts have not addressed whether “an appraisal for valuation may include some consideration of underlying liability, as long as it does not constitute a determination of coverage.” QBE, 778 N.W.2d at 399 (noting clear delineation in Minnesota law between valuation issues, which are decided by appraisers, and coverage issues, which are decided by courts). Other jurisdictions have distinguished an appraisal for “amount of loss,” which may include considerations of causation or liability when the insurer has admitted some covered loss, from the determination of an insured’s right to recover, which may not be decided by appraisers. See Rogers v. State Farm Fire & Cas. Co., 984 So.2d 382, 392 (Ala.2007) (<HOLDING>); Jefferson Ins. Co. v. Superior Court of
holding under the policy language that diminution of market value is not a cause of loss but a measure of a loss caused by something else holding that the loss of a contract failed to constitute ascertainable loss under cutpa holding that the failure to place a dollar value on a possible decrease in property value was not unreasonable holding that loss of an arm includes loss of the hand holding that contract language referring to amount of loss authorized appraiser only to place dollar value on loss and not to determine cause of damage or other coverage issues