Updated April 11, 2022

Matching is one of the more difficult topics in insurance. When only part of the property is damaged—such as siding or a roof—and if the carrier cannot match the existing property, should the entire property be replaced in order to properly indemnify the insured, or is it acceptable for the carrier to simply repair the property and leave the roof or siding mismatched?

When replacement cost coverage is available, logic would dictate that "new for old" would apply and the entire item should be replaced; with mismatched siding, shingles, or other property, the value of the property is diminished. However, various courts have found for both options; some state the entire thing should be replaced, while others have found that repairs, even if they do not match, are acceptable.

The following chart shows which states have laws in their books directly addressing the matching issue and which states use case law and generally accepted insurance principles. States with statutes that deal with matching are written in boldface type.

Note: All of the cases and statutes cited below are still good law—they have not been abrogated, overruled, or limited—as of the time of publication of this article.

State/Territory Matching Requirements Citations
Alabama In Alabama, insurance contracts are construed liberally in favor of the insured and strictly against the insurer. Pritchett v. State Farm Mut. Auto. Ins. Co., 834 So. 2d 785 (Ala. Civ. App. 2002)
Alaska Any person adjusting, negotiating, or settling a property claim on the basis of replacement cost. . . for a loss that requires replacement of property, and if the replacement property does not match in quality, color or size, shall replace the property in the area to provide for a reasonably uniform appearance; this paragraph applies to interior and exterior losses; the claimant is not require to pay for betterment or any other cost except for the applicable deductible. 3 Alaska Admin. Code 26.090
Arizona The reasonable expectations doctrine for insurance claims states that when insurance terms cannot be understood by the reasonably intelligent consumer, the court will interpret them in light of reasonable expectations of the average insured. Thus, matching can be enforced when contract allows for it or when consumer reasonably believes contract allows for it, even when it does not. Hanks v. Am. Family Mut. Ins. Co., 2013 U.S. Dist. LEXIS 73186 (D. Ariz. 2013)
Arkansas In the face of an ambiguous policy, a court will construe the policy liberally in favor of the insured and strictly against the insurer. Acceptance Indem. Ins. Co. v. Southwest Ark. Elec. Coop. Corp., 2014 Ark. App. 364 (Ark. Ct. App. 2014)
California When a loss requires replacement of items and the replaced items do not match in quality, color or size, the insurer shall replace all items in the damaged area so as to conform to a reasonably uniform appearance. This rule applies to both first-party residential and commercial property claims. 10 Cal. Code Regs. 2695.9
Colorado Words and phrases in an insurance policy are ascribed their plain meaning unless the language is ambiguous. Contracts should be interpreted in a manner that allows maximum effectiveness when viewing the policy as a whole. Hamlet Condo. Ass'n v. Am. Family Mut. Ins. Co., 2017 Colo. Dist. LEXIS 1433 (Col. Dist. Ct. 2017)
Connecticut When a covered loss for real property requires the replacement of an item or items and the replacement item or items do not match adjacent items in quality, color or size, the insurer shall replace all such items with material of like kind and quality so as to conform to a reasonably uniform appearance. This provision shall apply to interior and exterior covered losses. Conn. Gen. Stat. Ann. §38a-316e 
Delaware When an insurance policy is found to be ambiguous, the rule of contra preferentum requires that the policy be interpreted against the insurance company that drafted it. Stating policy terms in clear and unambiguous language is the insurer's responsibility. O'Brien v. Progressive N. Ins. Co., 785 A2d 281 (Del. 2001)
DC An ambiguous policy provision requires that any doubts be resolved in favor of the insured, including those that could be read to require matching. Nat'l Presbyterian Church, Inc. v. GuideOne Mut. Ins. Co., 82 F. Supp. 3d 55 (D.D.C. 2015)
Florida When a loss requires replacement of items and the replaced items do not match in quality, color, or size, the insurer shall make reasonable repairs or replacement of items in adjoining areas. (property insurance) Fla. Stat. §626.9744
Georgia If the construction is doubtful, that which goes most strongly against the party executing the instrument or undertaking the obligation is generally to be preferred. Ga. Code Ann. §13-2-2
Guam A well settled general principle of insurance law is that, should ambiguities exist in the language of the policy provisions, they are to be liberally construed in favor of the insured. Yasuda Fire & Marine Ins. Co. v. Heights Enterprises, 1998 Guam 5 (Guam 1997)
Hawaii Where there is an ambiguity in a written contract, parol evidence is admissible to explain the intent of the parties, and intent becomes a question for the trier of fact. In interpreting contracts, ambiguous terms are construed against the party who drafted the contract. DiTullio v. Hawaiian Ins. & Guar. Co., 616 P.2d 221, 223 (1980)
Idaho If the court or jury is unable to determine the intent of the parties, then the ambiguity should be resolved against the party who used the ambiguity in drafting the contract. Werry v. Phillips Petroleum Co., 540 P.2d 792 (1975)
Illinois Where an insurance contract is ambiguous and it is not resolved by other evidence, the court must adopt any reasonable interpretation the policyholder suggests. Tribune Co. v. Allstate Ins. Co., 715 N.E.2d 263, 269 (Ill. App. Ct. 1999)
Indiana Ambiguous provisions in insurance policies are construed in favor of the insured, particularly those provisions that limit or exclude certain coverages. Erie Ins. Exch. v. Sams, 20 N.E.3d 182, 187 (Ind. Ct. App. 2014)
Iowa When a loss requires replacement of items and the replaced items do not match in quality, color or size, the insurer shall replace as much of the item as is necessary to result in a reasonably uniform appearance within the same line of sight. This provision applies to both interior and exterior losses. The insured will pay costs over the applicable deductible, if any. Iowa Admin. Code r. 191-15.44(507B)
Kansas When interpreting ambiguous policy terms, the interpretation most favorable to the insured must prevail. Graves v. Am. Family Mut. Ins. Co., 2015 U.S. Dist. LEXIS 95127 (D. Kan. 2015)
Kentucky If a loss requires replacement of items and the replaced items do not reasonably match in quality, color, or size, the insurer shall replace all items in the area so as to conform to a reasonably uniform appearance. This applies to interior and exterior losses for Fire-and-Extended-Coverage-Type Policies. The insured shall not bear costs over the applicable deductible. 806 Ky. Admin. Regs. 12:095, sec. 9(1)(b)
Louisiana The measure of property damage is the cost of restoring the damaged property to its former condition, where the thing damaged can be adequately repaired, unless the costs of such repairs is disproportionate to the property's value or constitutes economic waste. Requiring full rather than partial replacement is not manifestly unreasonable. North American Land Development v. Higginbotham, et al., (771 So. 2d 245, La. Ct. App. 2000)
Maine Extrinsic evidence is allowed if language is ambiguous. Interpretation is for a jury to decide. Lee v. Scotia Prince Cruises Ltd., 828 A.2d 210 (Me. 2003)
Maryland If a contract is ambiguous, the court must use outside evidence to determine the intent of the parties at the time they initially entered the contract.  John L. Mattingly Const. Co. v. Hartford Underwriters Ins. Co., 999 A.2d 1066, 1074 (Md. 2010)
Massachusetts An insurance policy must be interpreted in the plain meaning of the language and construed in the sense that the insured will be able to understand the scope of the policy coverage. McLaughlin v. Berkshire Life Ins. Co. of Am., 973 N.E.2d 685 (Mass. App. Ct. 2012)
Michigan If extrinsic evidence cannot clarify an ambiguous contract, the jury should find against the party who wrote the contract and in favor of the nondrafting party. Klapp v. United Ins. Grp. Agency, Inc., 663 N.W.2d 447, 455 (Mich. 2003)
Minnesota The phrase "comparable material and quality" does not necessarily require an exact color match, but the replacement material must be a reasonable color match to the existing material. Cedar Bluff Townhome Condo. Ass'n, Inc. v. Am. Family Mut. Ins. Co., 857 N.W.2d 290 (Minn. 2014)
Mississippi Ambiguities in insurance contracts are read to favor the insured, but that principle does not permit the creation of ambiguity where there is none. Boteler v. State Farm Cas. Ins. Co., 876 So. 2d 1067 (Miss. 2004)
Missouri Coverage provisions in an insurance policy are to be liberally construed in favor of the insured to provide the broadest possible coverage. Matching is not required by statute, but if a policy can be reasonably interpreted to require matching, it will be enforced. Alessi v. Mid-Century Ins. Co., Inc., 464 S.W.3d 529, 531 (Mo. Ct. App. 2015)
Montana In cases of uncertainty not resolved by MCA §§28-3-201 to 28-3-205, concerning the plain meaning and effect of the contract, the language of a contract should be interpreted most strongly against the party who caused the uncertainty to exist. The promisor is presumed to be that party. Mont. Code Ann. § 28-3-206
Nebraska When a loss requires replacement of items and the replacement items do not reasonably match in quality, color or size, the insurer shall replace all items in the area so as to conform to a reasonably uniform appearance. This applies to both interior and exterior losses under fire and extended coverage policies. 210 Neb. Admin. Code Ch. 60, 010
Nevada If an Insurance policy has any ambiguous terms, they will be interpreted so the policy will effectuate the insured's reasonable expectations. Century Sur. Co. v. Casino West, Inc., 329 P.3d 614 (Nev. 2014)
New Hampshire If more than one reasonable interpretation is possible, and one of those indicates coverage, the policy is ambiguous and will be interpreted in favor of the insured. Brickley v. Progressive N. Ins. Co., 7 A.3d 1215 (N.H. 2010)
New Jersey Insurance policies should be construed liberally in favor of insureds to the full extent fair interpretation will allow. Fortunato v. Highlands Ins. Group, 785 A.2d 963, 965 (N.J. Super. Ct. Law Div. 2001)
New Mexico As the parties to a contract of insurance lack equal bargaining power, any ambiguities in an insurance policy should be construed in favor of the insured as a matter of public policy. United Nuclear Corp. v. Allstate Ins. Co., 285 P.3d 644 (N.M. 2012)
New York When an insurance policy is open to more than one reasonable interpretation, it is ambiguous and must be construed in favor of the insured and against the insurer. Ferraro v. N. Country Ins., 2005 N.Y. Misc. LEXIS 3207 (N.Y. Civ. Ct. 2005)
North Carolina If a nontechnical word has more than one meaning in its ordinary usage, and there is no clear context to indicate such a meaning, the term must be given the meaning most favorable to the policyholder. Rouse v. Williams Realty Bldg. Co., 544 S.E.2d 609 (N.C. Ct. App. 2001)
North Dakota In cases of uncertainty not removed by the preceding rules, the language of a contract should be interpreted most strongly against the party who caused the uncertainty to exist. The promisor is presumed to be such party. N.D. Cent. Code Ann. §9-07-19
Ohio When an interior or exterior loss requires replacement of an item and the replaced item does not match the quality, color or size of the item suffering the loss, the insurer shall replace as much of the item as to result in a reasonably comparable appearance. This provision applies to fire and extended coverage policies. Ohio Admin. Code 3901-1-54
Oklahoma An ambiguous provision in an insurance policy will be construed according to the understanding of a reasonable person in the insured's position, even if it isn't necessarily what the drafter/insurer intended. Andres v. Okla. Farm Bureau Mut. Ins. Co., 227 P.3d 1102 (Okla. Civ. App. 2009)
Oregon If, after looking to a term's plain meaning and context within the policy, an ambiguous provision remains ambiguous, the court will resolve any doubts in favor of the insured and against the insurer. Gonzales v. Farmers Ins. Co., 196 P.3d 1 (Or. 2008)
Pennsylvania Interpreting an insurance policy is a matter for the court, not a jury. When a policy is ambiguous, the court will construe it in favor of the insured and against the insurer, because the insurer is the party that drafted the policy. Greene v. United Servs. Auto. Ass'n, 936 A.2d 1178 (Pa. Super. Ct. 2007)
Puerto Rico The interpretation of obscure stipulations of a contract must not favor the party who introduced the obscurity. 31 L.P.R.A. § 3478
Rhode Island When a loss requires replacement of items and the replaced items do not match in quality, color or size, the insurer shall replace all such items so as to conform to a reasonably uniform appearance. This applies to interior and exterior losses. The first-party claimant shall not bear any cost over the applicable deductible, if any. 230 RICR 020-40-2
South Carolina When the terms of an insurance policy create ambiguity, the court must interpret those terms liberally in favor of the insured and strictly against the insurer. Auto-Owners Ins. Co. v. Benjamin, 781 S.E.2d 137 (S.C. Ct. App. 2015)
South Dakota If an insurance policy's provisions are fairly susceptible to more than one interpretation, the rules are liberally construed in favor of the insured and against the insurer. Zoo Props., LLP v. Midwest Family Mut. Ins. Co., 797 N.W.2d 779, 780 (S.D. 2011)
Tennessee Unless and until a court finds that the policy language itself is ambiguous, it will not be construed against the insurer in favor of the insured. Black v. State Farm Mut. Auto. Ins. Co., 101 S.W.3d 427 (Tenn. Ct. App. 2002)
Texas If an insurance policy is ambiguous…it will be interpreted in favor of the insured. Bituminous Cas. Corp. v. Maxey, 110 S.W.3d 203 (Tex. App. 2003)
Utah When a loss requires replacement or repair of items and the repaired or replaced items do not match in color, texture, or size, the insurer shall repair or replace items so as to conform to a reasonably uniform appearance. This applies to interior and exterior losses under a fire or extended coverage type policy. The insured is only responsible for the applicable deductible. Utah Admin. Code R590-190-13
Vermont Interpretation of an insurance policy is guided by the perspective of a reasonable person applying for insurance; ambiguity is resolved in favor of the insured, but the court will not remove unambiguous terms the insurer used for its own benefit. Shriner v. Amica Mutual Insurance Co., 167 A.3d 326 (Vt. 2017)
Virgin Islands If a court finds the policy or part of it is ambiguous, then the ambiguity must be resolved in terms most favorable to the insured. Guardian Ins. v. Rahhal, 63 V.I. 420 (V.I. 2015)
Virginia When two or more interpretations of a policy provision are reasonable, the court will adopt the interpretation most favorable to the insured. TravCo Ins. Co. v. Ward, 736 S.E.2d 321 (Va. 2012)
Washington Where a clause in an insurance policy is ambiguous, the meaning and construction most favorable to the insured must be applied, even if different from the insurer's intentions. Queen Anne Park Homeowners Ass'n v. State Farm Fire & Cas. Co., 352 P.3d 790, 793 (Wash. 2015)
West Virginia When policy language is exclusionary, it will be strictly construed against the insurer to support the provision of indemnity for the insured. Cherrington v. Erie Ins. Prop. & Cas. Co., 745 S.E.2d 508 (W. Va. 2013)
Wisconsin If the language of an insurance policy is ambiguous, it should be resolved in favor of coverage. Wildin v. Am. Family Mut. Ins. Co., 638 N.W.2d 87, 89 (Wis. Ct. App. 2001)
Wyoming When the language of an insurance contract is ambiguous, the policy must be construed strictly against the insurer. Sonnett v. First Am. Title Ins. Co., 309 P.3d 799 (Wyo. 2013)