🩻 Damage Type · Underpayment Patterns

Wildfire / smoke damage: the underpayment playbook

Wildfire smoke claims have their own complications: volatile organic compounds, particulate infiltration, HVAC contamination, and proximity arguments that don't match the science.

How carriers underpay wildfire / smoke damage claims

The industry standard you can cite

IICRC S700

Standard for Professional Fire and Smoke Damage Restoration

IICRC
**Key provisions:** Defines smoke residue types (dry, wet, protein, oil/fuel) and cleaning methodology per type. Specifies HVAC system cleaning required when smoke is present in supply ducts. Addresses ozone vs. hydroxyl treatment. Content pack-out, off-site cleaning, and atmospheric deodorization protocols. **How to cite in a carrier dispute:** Use when carrier denies HVAC duct cleaning, pack-out, or treatment beyond surface wipe-down. Smoke residue type determines required method — wrong method = continued contamination + warranty exposure.

Recent court opinions on wildfire / smoke damage disputes

City & County of S.F. v. Public Employment Relations Bd.
California Court of Appeal · Filed 2026-06-22
American Academy of Pediatrics v. James Uthmeier
Court of Appeals for the Seventh Circuit · Filed 2026-06-22
Travis Lynn Rasmussen v. Sasha Nicole Rasmussen
Court of Appeals of Tennessee · Filed 2026-06-22
Newman v. LM General Insurance
Court of Appeals of Utah · Filed 2026-06-19
Logan Antigone v. Jay C. Taustin
Court of Appeals of Virginia · Filed 2026-06-16

See how much your wildfire / smoke damage claim was underpaid

Plug your carrier and estimate into the underpayment calculator. NAIC-grounded, instant.

Run the estimator →