Paid For a Time the Database Set

Short answer: Collision technicians are usually paid for the hours an estimating database says a job should take, not the hours it takes. Two federal appeals courts call that pay a commission, which is one of the three conditions for the overtime exemption. In one of those two cases the exemption was upheld; in the other the court sent the case back. The risk of a slow job lands on the technician.

By Anthony Braswell for Quorum Industries LLC, The Autobody Directory · Updated 2026-09-01 · How this was written, and what the machine may not do

How this page was produced: Researched, drafted and checked with AI assistance under human direction, and signed off by the named author. How this site is written

Nothing here is legal advice. It describes what court opinions, federal regulations, a federal wage series and one filed complaint say, with a source for each.

The arithmetic, written down by a federal appellate court

[ADJUDICATED] The clearest public description of how a collision technician gets paid is not in a trade magazine. It is in a 2007 opinion of the United States Court of Appeals for the Seventh Circuit, in a case the technicians lost. The defendant, Sterling Collision Centers, is described as "a chain of auto repair shops." Here is the court setting out the mechanism:

"It calculates the number of hours normally required to do a given type of repair (these are called 'booked hours') and multiplies that number by a dollar figure. The product of this multiplication is the labor price of the repair to the customer."

That is the price to the customer. The technician is paid out of a second calculation using the same booked hours:

"Sterling determines each member's compensation by multiplying (1) the number of booked hours for the job by (2) the ratio of the team member's actual hours worked to the total hours worked by the team, and then by (3) a wage, per booked (not actually worked) hour, based on the skill or quality of the individual team member."

The court worked an example: six booked hours for a headlight repair, a two person team finishing in three hours, one technician putting in two of them at a booked hour rate of $20. "That is 4 hours, and when multiplied by $20 per booked hour yields $80."

Read the two calculations together and the structure is visible. Both the price to the customer and the pay to the team start from the same booked hours figure and multiply it by a dollar rate. Actual hours enter once, on the pay side, and only as each member's share of the team's total hours, so they divide the money between the team rather than add to it. For a technician working alone the formula reduces to booked hours times his booked hour rate, and does not move if the car takes twice as long.

[REPORTED, our derivation from the opinion's own arithmetic, not a finding by any court] The shop's gross labour margin is therefore booked hours multiplied by the gap between the door rate and the rate paid per booked hour, and it does not change when a job runs long. Neither do the technician's earnings for that job. What changes is the technician's effective hourly rate. That is the risk transfer: under a plan that pays per booked hour, the variance in how long a repair takes falls on the person doing the repair rather than on the shop's margin for that job.

The Seventh Circuit described the same fact from its pleasant side, and used it as the reason the pay counts as a commission:

"The faster the team works, the more it earns per number of hours, since its commission is based not on the total number of hours it puts in on a job but on the number of booked hours times each team member's booked-hour rate. That is how commissions work; they are decoupled from actual time worked."

Decoupled is the court's word.

Where the booked hour comes from, and who is not in the room

[ADJUDICATED] The other federal appellate case we located on this subject answers the question the Seventh Circuit did not. In 2001 the Eleventh Circuit heard the case of an automobile painter at an auto repair and body shop, and said this about where his hours came from:

"The 'flag hours' were derived from a database utilized by auto repair shops and insurance adjusters. Thus, they did not necessarily reflect the actual time spent completing a job."

And on what followed: "If more than or fewer than the predetermined number of flag hours were required to complete a job, Swift would nevertheless pay the painter for the predetermined number of hours even though he did not actually work that many hours."

A federal court of appeals has recorded, as undisputed background, that the number setting a body shop worker's pay comes from a database shared with the people paying the claim.

[REPORTED] The databases are commercial products. MOTOR, one of the companies that publishes labour times, describes its Estimated Work Times in one sentence: "MOTOR Estimated Work Times are developed using MOTOR's proprietary data, analysis tools, and evaluation methodologies ensuring a consistent and independent standard for customer pay operations." Three things are in that sentence and all three matter. The vendor claims independence, which we cannot test and do not dispute. The method is proprietary, so no shop, technician or vehicle owner can reproduce the number. And the product described on that page is offered as a standard for customer pay work rather than for insurance claims. We did not obtain a comparable published description of the labour times used on an insurance estimate.

We are not saying the databases are wrong, or that anybody rigs them. We have no evidence of that and did not look for it here. What is established is narrower and stranger: the single number that fixes a shop's labour revenue, an insurer's labour payout and one worker's income for a job is set by a party to none of those three transactions, by a method none of them can inspect.

Why it is lawful, and the part that is not unanimous

[REPORTED, statute and agency guidance] The Fair Labor Standards Act requires overtime above forty hours in a week. Section 7(i) exempts commissioned employees of a retail or service establishment. The Department of Labor's Fact Sheet #20, revised July 2008, sets three conditions: employment "by a retail or service establishment," a regular rate that exceeds "one and one-half times the applicable minimum wage for every hour worked" in an overtime week, and commissions making up "more than half the employee's total earnings in a representative period." Miss any one and the exemption does not apply.

[ADJUDICATED] Both of the circuits whose flat rate auto repair decisions we located found the commission condition satisfied. The Seventh Circuit affirmed summary judgment for Sterling. It closed on what it expressly called "a more plausible hypothesis": that "the auto repair industry has been left alone because the character of its compensation system has been recognized for what it is", namely "a bona fide commission system." It also recorded that "The system of compensation used by Sterling is industry-wide, and of long standing."

[ADJUDICATED, and it cuts both ways in the same opinion] The Eleventh Circuit reached the same conclusion on commission six years earlier and still sent the painter's case back. It held that "Swift's flat rate system constitutes a form of commission payment," then vacated summary judgment because, in its own words, "there is not enough evidence in the record to determine whether Swift met the first component of the exemption requirement", the regular rate of pay. The reason is the practical weakness of the design: "Swift did not maintain records of the actual hours that Klinedinst worked," so "neither we nor the district court can ascertain" his regular rate. The order was "VACATED and REMANDED."

[DISPUTED] The commission holding was not unanimous. Judge Restani concurred in part and dissented in part: "By any ordinary understanding of the meaning of commissions, the payments to Klinedinst are not commissions," and "Not every method of payment which might encourage efficiency is a commission method." That dissent has not become law anywhere we found, but it sits inside the very opinion usually cited for the opposite proposition.

The condition the government removed in 2020

[REPORTED, final rule] The first condition, the retail or service establishment, is where this is currently open.

The Department of Labor has had no live statutory definition since 1989. As it explains, the term was defined in a section of the Act that Congress repealed that year, and the Department "continues to use the repealed section 13(a)(2) definition": "an establishment 75 per centum of whose annual dollar volume of sales of goods or services (or of both) is not for resale and is recognized as retail sales or services in the particular industry."

For decades the Department also published two lists: establishments it viewed as lacking a retail concept, at 29 CFR 779.317, and establishments that "may be recognized as retail," at 29 CFR 779.320. Automobile repair shops were on the second list, and we know it from an unusually good source: the Department's own 2020 rule quotes the Eleventh Circuit "citing Sec. 779.320 for the proposition that '[a]utomobile repair shops have been explicitly recognized as retail establishments'". The Eleventh Circuit text being quoted is a footnote, and it reads in its entirety: "Automobile repair shops have been explicitly recognized as retail establishments," followed by a bare citation to 29 CFR 779.320. It is an assumption stated in passing. The opinion contains no analysis of whether the shop was a retail or service establishment, and neither does the Seventh Circuit opinion above, which treats the point as given in its first paragraph.

On 19 May 2020, at 85 FR 29867, the Department published a final rule titled "Partial Lists of Establishments that Lack or May Have a 'Retail Concept' Under the Fair Labor Standards Act." Its operative amendments are two lines: "Remove and reserve Sec. 779.317" and "Remove and reserve Sec. 779.320." It took effect the day it was published.

A case by case test replaced the lists. The Department said it "will apply its interpretations set forth in Sec. 779.318 and elsewhere in part 779 to determine whether establishments previously listed in Sec. 779.320 have a retail concept." Under 779.318(a) such an establishment typically "sells goods or services to the general public," "serves the everyday needs of the community," and "is at the very end of the stream of distribution." Then, at the end of the same discussion: "Nothing in this action should be construed to suggest that any particular type of establishment previously listed by the Department is, or is not, a retail establishment."

So the categorical listing a federal appeals court pointed to in a 2001 footnote no longer exists, and the Department declined to say what its removal means for any particular business. Whether a modern collision company, and in particular a national operator whose largest customers are insurers rather than the people who own the cars, is a retail or service establishment under the replacement test is a question we did not find answered anywhere. We are not saying collision shops have stopped being retail establishments. We are saying the rule that answered it by name was withdrawn, the Department refused to say what follows, and we located no authority applying the replacement test to a collision company. Our case law searching was limited, so read that as not located rather than as does not exist.

What the federal wage data actually shows

[REPORTED] The figures below are Quarterly Census of Employment and Wages annual averages for NAICS 811121, private, national. We pulled every row ourselves on 2026-09-01 from www.bls.gov, whose robots file permits the /cew/ path, after reading that file first. The 2024 row was pulled twice, from two different files, and agreed to the digit.

Two limits travel with those numbers. Average annual pay here is the whole establishment's payroll divided by its whole employment, so it includes managers, estimators, parts and office staff, and a rise in it does not establish that a technician's pay rose as much. And it counts establishments, not owners: an acquisition moves a shop into a different company without closing it.

The comparison that cuts the other way

[REPORTED, our computation from rows we pulled] Between 2015 and 2024 average annual pay in collision repair rose from $45,935 to $67,639, up 47.2 percent. Over the same years, on the same instrument, average annual pay across all private industry in the United States rose from $52,876 to $75,850, up 43.4 percent.

Collision repair pay grew 3.8 percentage points faster than the private economy as a whole, and closed part of the gap to it: the industry paid 86.9 percent of the all private average in 2015 and 89.2 percent in 2024. Both figures are nominal and come from the same file for the same years, so the comparison needs no inflation adjustment and none was applied.

That cuts against the pay suppression version of this story, and it should. If a pay structure were reliably holding wages down, this is the series where you would expect to see it. It is not there.

The occupation against the whole labour market

[REPORTED] The occupational series is a different instrument, and its publisher warns about how it is used. Asked whether its data can show change over time, the Bureau of Labor Statistics says the survey "is less useful for looking at changes over time" and, flatly, "The Bureau of Labor Statistics does not encourage the use of OEWS data for time-series analysis."

So take the cross section, which is what the survey is designed for. In May 2023 the median hourly wage of an automotive body and related repairer was $23.43. The median for an American worker in any occupation whatsoever was $23.11. The body repairer was on 101.4 percent of the national median, thirty-two cents an hour ahead of the middle of the entire labour force, in a trade whose published duties include realigning "car frames and chassis to repair structural damage", welding "replacement parts into place" and applying "new finish to restored body parts", entered with a high school diploma and, per the Bureau's own handbook, "None" by way of prior work experience.

[REPORTED, our computation, and subject to the caution in the same breath] Laying two published cross sections beside each other, and repeating that the Bureau does not encourage the use of these data for time series analysis: between May 2016 and May 2023 the median hourly wage for body repairers rose 17.3 percent, from $19.97 to $23.43, while the all occupations median rose 29.8 percent, from $17.81 to $23.11. The premium the trade held over the national median in 2016, 112.1 percent, was 101.4 percent by 2023.

We do not claim that proves the occupation is falling behind. Two cross sections are not a trend, the caveat is the publisher's own, and the period contains a pandemic. We do claim this: anyone asserting an acute and worsening technician shortage is asserting something the available occupational pay statistics do not show, because a market clearing badly usually pays up faster than the market around it, and here it did not.

The most detailed pay plan we found at a national collision company, and it is an allegation

[ALLEGED, and nothing in it has been adjudicated] Almost nothing about how the largest collision companies actually pay people is public. The most specific description we located of pay at a named national collision company is a complaint, and it describes an estimator rather than a technician. On 12 May 2026 Glenn Lucero filed a collective and class action against Crash Champions, LLC in the Northern District of Illinois, No. 1:26-cv-05476, alleging failure to pay overtime under the Fair Labor Standards Act and the New Mexico Minimum Wage Act; Crash Champions filed an answer with affirmative and other defenses on 26 June 2026, and no court has found any part of the complaint proved. He worked as an estimator in New Mexico from about January 2020 to April 2025.

What the complaint alleges, and only alleges: that from December 2020 to January 2025 he was classified as exempt and salaried at "approximately $75,000" a year plus "a weekly sales-based bonus equal to approximately 11% of gross profit," while typically working "approximately forty-five (45) hours per week"; that after a January 2025 reclassification to hourly at "approximately $32.00 per hour," bonuses were left out of the overtime rate; and that one of those bonuses worked like this:

"The ATE bonus was a sales-based bonus calculated using a predetermined formula: Plaintiff was eligible to receive (a) set percentage of all monthly sales above $170,000 if the location's Net Promoter Score ('NPS') exceeded 88%; or (b) a lower set percentage of all monthly sales above $170,000 if the location's NPS was 88% or below."

If that is accurate, and only a court can decide whether it is, the person who writes the estimate at a national collision company was paid on a share of gross profit, and later on a share of sales above a threshold with the share set by a customer satisfaction score. The estimate is the document that sets the technician's pay. That is why the pleading matters beyond wage law, and why we will not treat it as fact. We are not claiming Crash Champions paid anyone this way. We are saying one complaint on one federal docket alleges it, the company has answered with defenses, and nothing has been decided.

The docket records "DEFENDANT'S ANSWER AND AFFIRMATIVE AND OTHER DEFENSES TO PLAINTIFF'S COLLECTIVE AND CLASS ACTION COMPLAINT" at entry 15, dated 26 June 2026, and no dismissal, settlement or judgment. The case is live before Judge Franklin U. Valderrama. We have not read the answer and do not characterise it beyond its existence.

A plan of the opposite shape, and it was upheld

[ADJUDICATED] The claim that production pay transfers duration risk to the worker is true of one plan shape, not of production pay in general, and the counterexample is on the record. In Certified Tire and Service Centers Wage and Hour Cases, filed 18 September 2018 and certified for publication on 4 October 2018, a California Court of Appeal described a plan in which "A technician's hourly rate for the applicable pay period is guaranteed to be at least an agreed-upon minimum hourly rate that the technician is assigned at the time of hire, which in all cases exceeds the legal minimum wage." Production is counted, but the arithmetic divides by clock time: the company multiplies production dollars by 95 percent, then by a fixed "tech rate," then divides "by the total hours worked by the technician during the pay period." And technicians "are required to be clocked in during all work hours, except for their lunch period, and they are paid at an hourly rate for all hours on the clock."

The judgment for the employer was affirmed. Certified Tire is a tyre and general service chain, not a collision company, and the case is California law, so it is a design comparison and not authority about collision repair.

The difference is the point. Where the denominator is hours actually worked and a floor catches the bottom, a slow job lowers the rate but never removes the pay for the hour. Where the denominator is booked hours and there is no floor, it does.

The case for flat rate, stated as strongly as we can source it

Flat rate rewards a fast, skilled technician, and the record contains real evidence of it.

[REPORTED, agency guidance quoted verbatim in the Eleventh Circuit's opinion] The Department of Labor's Field Operations Handbook describes the upside without embarrassment: "A 'flat rate' hour is not an actual clock hour. The painter or mechanic may work only 7, 8 or 9 hours a day and still receive credit for 10, 11 or 12, etc., flat rate hours depending upon how much work he or she has done." The same opinion describes the system as "a method of providing employees with an incentive to 'hustle' to finish their jobs in order to obtain a larger number of jobs for greater compensation." The Handbook is not law and the court said so in the same passage: agency internal directives "are without the force of law," the Handbook is "not entitled to Chevron deference," and the court used it because "we find it persuasive."

[ADJUDICATED] In the Sterling case the two named plaintiffs "earn more than $60,000 a year; their booked-hour rates are $21.50 and $18.50 and their actual hourly rates considerably higher." That is 2007 money, and a court recording that the men bringing the case were doing well out of the arrangement. The court noted the class was said to include workers paid much less, and observed that none of them was a class representative.

[ADJUDICATED] An employer said as much under oath and won. Certified Tire's president "testified that he designed the TCP to incentivize technicians 'to hustle' to get things done, and to make Certified Tire a more competitive employer in the industry by allowing technicians to significantly increase their hourly compensation based on their efficiency without any cap on the amount of compensation." The same opinion records his evidence that "some technicians achieve a base hourly rate of up to $70 per hour during a pay period."

[REPORTED] The top of the distribution is real: in May 2023 the ninetieth percentile automotive body repairer earned $38.65 an hour, or $80,380 a year, against $23.43 an hour at the occupation's median and $16.95 at its tenth percentile. All three come from one published table, so the spread is measured on a single basis. And the pay comparison above is the strongest fact here in the industry's favour.

What we did not find is a named collision technician, on the record, saying he prefers flat rate. We looked and did not get one. That gap is ours, not the industry's, and the most important voice here is missing from it.

What we could not establish, and the walls that stopped us

• A real terms wage figure. No inflation deflator was obtainable through a permitted route, so no claim about real wages appears above and none may be derived from anything here. The pay comparison above sidesteps it by benchmarking two nominal series for the same years.
• Whether any named collision company uses pure flat rate today. No pay plan document from a national operator was obtained. The most detailed plan we found at a named national collision company is an allegation about an estimator. The one fully described technician plan in this article, Certified Tire's, comes from a published opinion about a tyre and general service chain.
• Whether a collision company is a retail or service establishment under 29 CFR 779.318 after the 2020 withdrawal. No authority applying that test to one was located here.
• The subsequent history of the California decision cited. The California appellate case system returned the record for D072265 on 2026-09-01 but no later history, so whether review was sought or denied is not established here. No legal rule in this article rests on that case. It is used only as a description of a pay plan and for the fact of the affirmance.
• WALL: data.bls.gov. Retested 2026-09-01. Its robots file names every user agent and then disallows every path on the host, and it serves the QCEW table maker and the download links on the Bureau's own pages. Nothing here came from it. The identical data is served by www.bls.gov, which permits the path.
• A retrieval client that refused a path the site permits. One of our two fetchers returned a robots disallowed error for https://www.bls.gov/cew/data/api/2024/a/area/US000.csv while fetching other pages on the same host without complaint. We then read https://www.bls.gov/robots.txt in full through two separate clients. For every user agent it disallows /scripts, /crs, /_private, /iisadmin, /srchadm, /advisory/members/, /idcf and any path containing the word print, and it does not disallow /cew/. The host served the file with HTTP 200, content type text/csv, and no redirect to any other host. The refusal was our client, not the site.
• WALL: www.bls.gov, from one of our two machines. Every request from that machine, including the request for robots.txt itself, returned HTTP 403. That is an address level block on our side rather than a rule the Bureau publishes, and the figures above were taken through the route that the Bureau's own robots file permits.
• WALL: an Apify scraping actor behind an account permission gate. The actor that would have filtered the CSV server side required account level approval, so it was not run. The files were filtered locally instead.
• WALL: law.resource.org. Its robots file names ClaudeBot among the crawlers it blocks, so it was not fetched. Court quotations above came from elsewhere.
• WALL: federalregister.gov and ecfr.gov, for one class of client. Both returned a gate reading "Due to aggressive automated scraping" to one retrieval route while answering another: a wall wearing an HTTP 200.
• Instrument control. Every absence claim above followed the same tool finding something on the same source. The QCEW files that we say hold exactly one national private row for NAICS 811121 also returned, from the same fetch, the row for all private industry and a separate row for NAICS 811122, at over 4,500 lines each. The files answer, so the matches are real. Both court opinions were re-pulled in full through two independent routes, whitespace was flattened, and every quotation from them was string-matched against that text rather than read back off a summary. Where a first match failed it failed on typography, not on wording: nested quotation marks converted from double to single inside a block quote, and a hyphen artefact introduced by extracting text from a filed PDF.

Rejected

Claims available to this article that did not survive checking:

• "The Eleventh Circuit rested its retail establishment holding on 29 CFR 779.320." Overstated. The opinion assumed the point in a footnote, and the article states what that footnote says.
• The truncated version of the Seventh Circuit's central sentence. A form of it ending at "the number of booked hours" does not appear in the opinion. The sentence continues "times each team member's booked-hour rate," and we string-matched both the full sentence and the truncated form against the opinion text through two separate retrieval routes: the full form is present in both, the truncated form in neither. Quoted in full above.
• A caveat that a 2022 reclassification folded automotive glass replacement into NAICS 811121. Our own pull contradicts it: NAICS 811122 appears as a separate national private row in every QCEW file we fetched, 2015 through 2024, with 7,163 establishments in 2024. The classification documents say the same thing. Census's 2017-to-2022 NAICS concordance maps 811121 to 811121 and 811122 to 811122, each with no change flag, and the 2022 NAICS structure file still lists 811122, Automotive Glass Replacement Shops, as its own six-digit code. There was no fold, so no adjustment is owed to any figure above.
• "The complaint alleges he was responsible for inspecting damaged vehicles." That paragraph is about estimators generally, not the plaintiff.
• Any inflation adjusted wage figure. No deflator was obtainable, so no figure. Every quotation above was re-fetched from its source on 2026-09-01, and anything that would not re-fetch is not in the article.

Corrections

2026-09-01, cross-article audit. No figure or quotation above changed. One rejected caveat gained the document that settles it: another page in this series had published the claim that NAICS 2022 folded automotive glass replacement into 811121 and had adjusted its conclusions for it. That page has been corrected. The rejection above, which rested on our own QCEW pull, now cites the Census concordance and structure file as well, so the two pages resolve the same way against the same primary.

2026-09-01, two robots.txt directives quoted verbatim, now described instead. The walls section above quoted the Bureau of Labor Statistics robots files exactly, which meant printing the wildcard character that stands for every user agent, and a path pattern containing the same character. This site's renderer implements bold but not italic, so a stray asterisk reaches the reader as an asterisk, and a pre-deploy gate caught two of them pairing across a paragraph into a run of literal markup. The directives are now stated in words rather than reproduced: "names every user agent and then disallows every path on the host", and "any path containing the word print". Nothing about which paths are permitted or refused has changed, and the robots file itself is linked in the sources so a reader can check the wording against the original. Recorded because turning a quotation into a paraphrase is exactly the kind of edit that should never happen silently.

Related

• How much of a body shop's work comes from one insurer
• The sign on the shop is not the name on its safety record
• What a collision technician is paid in every state

Sources

• Yi v. Sterling Collision Centers, Inc., 480 F.3d 505 (7th Cir. 2007), full opinion: https://law.justia.com/cases/federal/appellate-courts/F3/480/505/617172/ and, as a second retrieval route for the same text, https://openjurist.org/480/f3d/505 Both read on 2026-09-01.
• Klinedinst v. Swift Investments, Inc., 260 F.3d 1251 (11th Cir. 2001), opinion and partial dissent: https://law.justia.com/cases/federal/appellate-courts/F3/260/1251/494804/ and, as a second retrieval route for the same text including footnote 5, https://openjurist.org/260/f3d/1251 Both read on 2026-09-01.
• Department of Labor final rule, 85 FR 29867, 19 May 2020, official text: https://www.govinfo.gov/content/pkg/FR-2020-05-19/html/2020-10250.htm Read on 2026-09-01.
• Wage and Hour Division Fact Sheet #20, revised July 2008: https://www.dol.gov/agencies/whd/fact-sheets/20-flsa-commissions-retail Read on 2026-09-01.
• Lucero v. Crash Champions, LLC, N.D. Ill. No. 1:26-cv-05476, complaint filed 12 May 2026: https://www.classaction.org/media/lucero-v-crash-champions-llc.pdf and docket https://dockets.justia.com/docket/illinois/ilndce/1:2026cv05476/500498 Read on 2026-09-01.
• Certified Tire and Service Centers Wage and Hour Cases, No. D072265, Cal. Ct. App. 2018: https://law.justia.com/cases/california/court-of-appeal/2018/d072265.html Read on 2026-09-01.
• BLS Quarterly Census of Employment and Wages, annual averages, private, national, from https://www.bls.gov/cew/data/api/YEAR/a/area/US000.csv for 2015, 2019, 2021, 2023, 2024, cross-checked against https://www.bls.gov/cew/data/api/2024/a/industry/811121.csv Read on 2026-09-01. Permission read first at https://www.bls.gov/robots.txt Read on 2026-09-01.
• US Census Bureau NAICS classification files, for the 811121 and 811122 codes: 2017 to 2022 concordance, https://www.census.gov/naics/concordances/2017_to_2022_NAICS.xlsx , and 2022 structure, https://www.census.gov/naics/2022NAICS/2022_NAICS_Structure.xlsx Read on 2026-09-01.
• BLS Occupational Employment and Wage Statistics, SOC 49-3021 and the all occupations row: https://www.bls.gov/oes/2023/may/oes493021.htm , https://www.bls.gov/oes/2023/may/oes_nat.htm , https://www.bls.gov/oes/2016/may/oes493021.htm , https://www.bls.gov/oes/2016/may/oes_nat.htm Read on 2026-09-01.
• BLS OEWS FAQ, on time series use: https://www.bls.gov/oes/oes_ques.htm Read on 2026-09-01.
• California appellate case record for D072265, searched for subsequent history: https://appellatecases.courtinfo.ca.gov/search/searchResults.cfm?dist=41&search=number&query_caseNumber=D072265 Read on 2026-09-01.
• BLS Occupational Outlook Handbook: https://www.bls.gov/ooh/installation-maintenance-and-repair/automotive-body-and-glass-repairers.htm Read on 2026-09-01.
• MOTOR Estimated Work Times: https://www.motor.com/products-services/data-products/estimated-work-times/ Read on 2026-09-01.

General consumer information: not legal, insurance, or financial advice. Requirements, coverage, and practices vary by state, policy, and manufacturer.

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