James River Insurance Company v. Rapid Funding, LLC

Rapid Funding (plaintiff) submitted a $3 million fire-insurance claim on a destroyed apartment building; James River (defendant) denied it, claiming the building was worth less than $0 beforehand. At trial, Rapid Funding's principal, Miller, testified as a lay witness about the building's value, relying on renovation-versus-reconstruction cost estimates, depreciation adjustments, and an outside expert's report. The jury awarded Rapid Funding over $5 million, and James River appealed, arguing Miller's testimony was inadmissible lay opinion or, alternatively, improperly admitted expert testimony.