Here is the damage rule for clothing, furnishing, etc. Note that it is not mere replacement value or fair market value (which would be garage sale value):
We have found no direct authority on measuring the value of food purchased for personal consumption. But for household goods having no recognized market value, we have held the measure of damages is the value to the owner:
[T]he trier of fact may consider, in determining the actual value to the owner at time of loss, the original cost, cost of replacement, opinions of qualified witnesses, including the owner, the use to which the property was put, as well as any other reasonably relevant facts.
Allstate Ins. Co. v. Chance, 590 S.W.2d 703, 704 (Tex.1979). It is well settled that a property owner may opine about the property's value. Porras v. Craig, 675 S.W.2d 503, 504 (Tex.1984).
In some situations, replacement value does not properly measure damages because it may represent an economic gain to the plaintiff. Crisp v. Sec. Nat'l Ins. Co., 369 S.W.2d 326, 328 (Tex.1963); Pasadena State Bank v. Isaac, 149 Tex. 47, 228 S.W.2d 127, 128 (1950). This may be true for household goods, clothing, and personal effects. Crisp, 369 S.W.2d at 328. The measure of damages for the destruction of such items is the "actual worth or value of the articles to the owner for use in the condition in which they were at the time of [the injury] excluding any fanciful or sentimental considerations." Id. In determining damages, the jury has discretion to award damages within the range of evidence presented at trial. Price Pfister, Inc. v. Moore & Kimmey, Inc., 48 S.W.3d 341, 352 (Tex.App.-Houston [14th Dist.] 2001, pet. denied).
Gulf States Utilities Co. v. Low, 79 S.W.3d 561, 566 (Tex. 2002)