The U.S. Court of Appeals for the 5th Circuit in Mitchell v. State Farm Fire and Cas. Co., 954 F.3d 700 (5th Cir. 2020), applying Mississippi law, held that State Farm’s definition of actual cash value was ambiguous and therefore had to be interpreted in the homeowners’ favor. The State Farm policy did not define actual cash value and the Court found that the term “actual cash value” by itself was ambiguous as a matter of law. Thus, labor costs were part of ACV.