A Texas federal judge has excluded two experts' Xactimate-based damage opinions after finding that numerous adjustments to pricing, labor rates, and repair quantities lacked sufficient justification.

In a September 16, 2026, ruling in Trinity Fellowship Church of Pampa v. Church Mutual Insurance Company, U.S. District Judge Matthew Kacsmaryk determined that the methods used by two policyholder experts were unreliable, excluding their damage-estimate opinions from being presented to a jury as expert testimony.

Disputed Estimates and Court Findings

The case involved property damage following a June 2023 storm in Pampa, Texas. The insurer and policyholder disagreed over the extent of the damage and the estimated repair costs.

Two experts representing the policyholder, Monty Stone and Chase Brewer, prepared damage estimates using Xactimate, a widely used property insurance estimating platform.

According to the court, Brewer's initial estimate was approximately $1.34 million in 2023. A revised estimate in September 2024 reached approximately $6.45 million, despite a nearly identical scope of work.

The court examined 27 examples of disputed estimating practices identified by the insurer, including:

• Material pricing: Roofing replacement costs exceeding standard Xactimate pricing without sufficient justification.

• Labor rates: Higher labor classifications and rates substituted without adequate supporting evidence.

• Material quantities: Additional roofing waste included beyond allowances already incorporated into certain line items.

• Repair specifications: Changes to roofing materials and insulation assemblies without sufficient supporting documentation.

• Additional charges: Percentage-based charges and markups applied without adequate explanation.

The judge concluded that the alterations reflected an unreliable estimating methodology and excluded both experts' damage-estimate opinions in their entirety.

The ruling does not prohibit adjustments to Xactimate estimates. Property losses often require modifications to account for actual repair conditions, specialized materials, regional labor costs, and other factors that standard estimating software may not fully capture. However, estimates presented as expert evidence in litigation must be supported by reliable methods and sufficient evidence.

The decision did not establish the correct cost of repairs or resolve the underlying insurance dispute.

Relevance to Agricultural Property Claims

Although the case did not involve agricultural property, similar estimating considerations apply to farm and ranch and commercial agricultural claims.

Grain facilities, livestock buildings, equipment storage structures, and other agricultural properties can involve specialized materials, construction methods, and repair requirements that may not fit standard estimating categories.

Adjustments to estimating software may be necessary to reflect these conditions, but they should be supported by documented damage, actual repair requirements, and reliable cost information.

The ruling underscores the importance of being able to explain and defend the methods used to develop property damage estimates, particularly when those estimates become part of disputed insurance claims.

Source: U.S. District Court for the Northern District of Texas — Memorandum Opinion and Order, September 16, 2026