In American Guarantee & Liability Ins Co. v. 51 Roses Mill LLC, the United States District Court for the District of Connecticut found that a post loss assignment of benefits included the assignee ability to apply and collect recoverable depreciation though it had not accrued at the time of the assignment. The Court held that once the loss had occurred, any and all insurance proceeds arising from the loss, including recoverable depreciation, became assignable, regardless of the conditions necessary to receive the proceeds.