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Why Claims Against Insurers Almost Never Succeed

Short answer: Not the antitrust exemption. The four appellate opinions we read in the body shop antitrust litigation never name the McCarran-Ferguson Act. These cases die on pleading standards, class certification rules, who owns the cause of action, and whether a lawyer can be paid.

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

Claims against auto insurers almost never succeed, and the reason is not the antitrust exemption everyone cites. The common explanation is that the McCarran-Ferguson Act immunises insurance companies from federal antitrust law, so cases about steering, labour rates and total-loss valuation are lost before they are filed. That explanation is wrong on the controlling Supreme Court test, and wrong on the record of the multidistrict body-shop antitrust litigation itself.

What actually happens is less dramatic and harder to fix. The cases die on procedure: on what a complaint must allege before any documents change hands, on whether small claims can be tried together, on who owns the cause of action, and on whether a lawyer can be paid. None of those four rules asks whether the insurer did anything wrong.

This page describes published opinions, statutes and official records. It is not legal advice, and nothing on it is a substitute for a lawyer licensed in your state.

The explanation that is wrong

Start with what the exemption covers. In Group Life and Health Insurance Co. v. Royal Drug Co., 440 U.S. 205 (1979), the Supreme Court held that a health insurer's agreements with participating pharmacies were not the business of insurance at all. The line it drew is the whole doctrine in nine words: "The exemption is for the 'business of insurance,' not the 'business of insurers'". The pharmacy contracts, it said, "do not involve any underwriting or spreading of risk, but are merely arrangements for the purchase of goods and services by Blue Shield." Cost savings did not save them: "Such cost-savings arrangements may well be sound business practice, and may well inure ultimately to the benefit of policyholders in the form of lower premiums, but they are not the 'business of insurance.'"

Three years later the Court reduced that reasoning to a test. Union Labor Life Insurance Co. v. Pireno, 458 U.S. 119 (1982) asks "first, whether the practice has the effect of transferring or spreading a policyholder's risk; second, whether the practice is an integral part of the policy relationship between the insurer and the insured; and third, whether the practice is limited to entities within the insurance industry." A chiropractic peer-review panel used to decide whether treatment was necessary failed all three prongs. On the third, the Court drew the line that matters here. Because the panel's evaluation did not bind the insurer, "at most, peer review is merely ancillary to the claims adjustment process," and "We see no reason that such ancillary activities must necessarily enjoy the McCarran-Ferguson exemption from the antitrust laws."

Now apply that test to an insurer's dealings with a collision repair shop. A labour-rate schedule does not spread a policyholder's risk; the risk transfer happened when the policy was sold, and paying a repairer is performance, not underwriting. A direct repair program agreement is not an integral part of the insurer-insured relationship, because the shop is not a party to it. And a body shop is not an entity within the insurance industry. Insurer-to-shop arrangements are cost-containment deals with third-party providers, which is Royal Drug exactly. On the face of the controlling test they are not the business of insurance, and the exemption does not reach them.

We are not claiming that any court has adopted that reading. No decision applying the Pireno criteria to an insurer-repairer arrangement was located for this article, and the application above is offered as reasoning, not as holding.

The record of the body-shop litigation settles the narrower point. Multidistrict Litigation 2557, In re Auto Body Shop Antitrust Litigation, produced four Eleventh Circuit opinions: the panel decision of September 7, 2017 in Nos. 15-14160, 15-14162, 15-14178, 15-14179 and 15-14180, which briefly revived the claims and was vacated on April 6, 2018 when the court voted to rehear the case en banc; the en banc decision of March 4, 2019 in the same five appeals, which killed them; Crawford's Auto Center, No. 17-12583, of December 20, 2019; and Automotive Alignment and Body Service, Nos. 16-13596 and 16-13601, of March 6, 2020. The full text of all four was searched for this article. Not one of the four names the McCarran-Ferguson Act, and not one of the four applies an antitrust exemption to anything.

We do not claim that no defendant ever raised the Act in this litigation. The district court orders and the party briefs were not obtained, so the boundary of that finding is the four appellate opinions plus the April 6, 2018 order that vacated the panel decision and took the case en banc, all five of which were searched in full text.

The Act does surface in the litigation, and where it does it points the other way. In the group-boycott section, the panel and the en banc court each cite 15 U.S.C. section 1013(b) alongside Sherman Act section 1 for the proposition that boycotting is prohibited. Section 1013(b) is part of the McCarran-Ferguson Act, and it is the part that takes the exemption away: "Nothing contained in this chapter shall render the said Sherman Act inapplicable to any agreement to boycott, coerce, or intimidate, or act of boycott, coercion, or intimidation." Both courts pair it with St. Paul Fire and Marine Insurance Co. v. Barry, 438 U.S. 531 (1978), the Supreme Court's boycott-exception case. In these four opinions, the one provision of the Act the Eleventh Circuit had occasion to apply is the provision that removes the exemption.

What killed the cases was the pleading standard. The en banc court, in an opinion by Judge Anderson, affirmed dismissal of price fixing, group boycott, unjust enrichment and quantum meruit. It began from the proposition that "[a]n allegation of parallel conduct and a bare assertion of conspiracy will not suffice." Matching prices proved nothing, because "Following the example set by a competitor, without agreeing to do so in advance, is textbook 'price leadership'", which the court called "a practice we have repeatedly stated is insufficient to establish the existence of an agreement." The shops had given no plausible reason to expect that prices in a market "involving standardized automobile parts and repairs" would be divergent in the first place. As for steering, "None of these tactics could even be fairly described as novel, let alone idiosyncratic, so as to support an inference of an agreement."

The RICO claim in Crawford's failed because disclosure defeated it. The shops "affirmatively allege they received Defendants' estimates prior to performing any repairs," and "knew the price Defendants were willing to pay up front, and this bars their claim that Defendants misrepresented the figures in the estimates." At most, the court held, "these Defendants drove a hard bargain." Announcing the take-it-or-leave-it price in advance is, under this line of authority, the defence rather than the evidence. In that opinion no immunity was needed, and none was invoked.

Shield one: the class certification rule

The strongest barrier is Rule 23(b)(3), which lets a class proceed only where "the questions of law or fact common to class members predominate over any questions affecting only individual members." In total-loss valuation cases that sentence does all the work.

Lara v. First National Insurance Company of America, a published Ninth Circuit decision of February 11, 2022, states the mechanism in three sentences. The insurer's vendor applied a downward condition adjustment to comparable vehicles in every valuation. The court wrote: "Whether Liberty and CCC's condition adjustment violates the Washington state regulations is a common question. But to show liability for breach of contract or unfair trade practices, Plaintiffs must also show an injury. And to show an injury will require an individualized determination for each plaintiff." And then the sentence that explains why uniformity of the practice does not help: "While the condition adjustment here is applied across the board, other compensating adjustments and the ultimate valuation are made individually."

Read that again. The uniformity of the practice is conceded and its legality is a common question, and the class still fails, because under Washington law the insurer owes only the "actual cash value" of the car, which the regulation and the court equate with "fair market value," and every claimant must separately prove they got less than that. Whether the adjustment was lawful is left undecided on that route.

Contrast Sos v. State Farm, No. 21-11769, an unpublished Eleventh Circuit decision of August 30, 2023, where certification and the breach-of-contract holding were affirmed and only the attorney's-fee award was disturbed. The disputed items were full sales tax and title transfer fees on totalled leased vehicles: contract interpretation followed by arithmetic. The court applied the rule of Carriuolo v. General Motors Co., 823 F.3d 977 (11th Cir. 2016), that "individualized damages calculations are insufficient to foreclose the possibility of class certification, especially when, as here, the central liability question is so clearly common to each class member."

The line between the two cases is the line between an entitlement and a judgment. Sales tax is a number the policy either owes or does not. Fair market value is an opinion about one used car.

On the Sixth Circuit's own list of aligned decisions as of April 2026, six federal circuits have now closed the valuation side of that line. The Sixth Circuit, sitting en banc in Clippinger v. State Farm on April 24, 2026, reversed certification of a class of 90,000 Tennessee policyholders whose total-loss payments had been reduced "based upon typical negotiation adjustments" for comparable vehicles. One question, the court held, "likely will dominate" the common ones: the actual cash value of each class member's vehicle. Determining fair market value "requires an independent and individualized assessment of each absent class member's property." The opinion aligns itself by name with five other circuits: Ambrosio, 154 F.4th 1107 (9th Cir. 2025); Freeman, 149 F.4th 461 (4th Cir. 2025); Schroeder, 146 F.4th 567 (7th Cir. 2025); Drummond, 142 F.4th 149 (3d Cir. 2025); and Sampson, 83 F.4th 414 (5th Cir. 2023).

In the decisions read here, mechanical underpayments certify and judgment-based ones do not. The most systematic category of collision-adjacent underpayment, how a totalled car is valued, is now litigable across six federal circuits one car at a time.

Shield two: who owns the claim

Bad faith is the cause of action people reach for, and where it exists it runs to the insured. A repair shop is not the insured under its customer's policy. It is a stranger to that contract, which is why MDL 2557 was pleaded in antitrust, RICO and tort instead. Pennsylvania's statute makes the point on its face: 42 Pa.C.S. section 8371 provides remedies where "the insurer has acted in bad faith toward the insured," and lists interest, punitive damages, and costs and fees. There is no compensatory damages entry and no repairer anywhere in it.

For third-party claimants the position is worse. In Moradi-Shalal v. Fireman's Fund Insurance Cos., 46 Cal. 3d 287 (1988), the California Supreme Court held that "Neither section 790.03 nor section 790.09 was intended to create a private civil cause of action against an insurer that commits one of the various acts listed in section 790.03, subdivision (h)." It surveyed the rest of the country as it stood in 1988 and reported its own count: nineteen states other than California had faced the question, and "The courts in 17 of these 19 states have refused to recognize such a cause of action, either expressly rejecting the Royal Globe analysis, or interpreting statutory language similar to sections 790.03, subdivision (h), and 790.09 in a manner contrary to Royal Globe without mentioning that case." What survives, the court said, are common-law theories, and the covenant of good faith is reserved by an explicit parenthetical: "fraud, infliction of emotional distress, and (as to the insured) either breach of contract or breach of the implied covenant of good faith and fair dealing."

Florida runs the other way and shows what a real third-party remedy looks like. Fla. Stat. 624.155 opens "Any person may bring a civil action against an insurer when such person is damaged". Even there a brake is built in: "No action shall lie if, within 60 days after the insurer receives notice from the department ... the damages are paid or the circumstances giving rise to the violation are corrected." The statute creates a right and a window to buy it off in the same breath.

Shield three: a model law written not to be enforceable

Nearly every state prohibits the same list of unfair claim practices, because nearly every state adopted a version of the same NAIC model. The list is not the question. Standing is.

The NAIC Unfair Claims Settlement Practices Act, Model Law 900 says: "Nothing herein shall be construed to create or imply a private cause of action for violation of this Act." The drafting note that follows is the single most useful sentence in this area of law and is almost never quoted:

"A jurisdiction choosing to provide for a private cause of action should consider a different statutory scheme. This Act is inherently inconsistent with a private cause of action. This is merely a clarification of original intent and not indicative of any change of position."

On the drafters' own note, the prohibition was designed to be enforced by the insurance commissioner and by nobody else. When a shop or a policyholder reads that list in their state's insurance code and concludes they can sue on it, the drafters say otherwise. The conduct is unlawful and the person injured by it generally cannot bring the case.

Shield four: arithmetic

Judge Posner put the economics of small claims more plainly than any court since. In Carnegie v. Household International, Inc., 376 F.3d 656 (7th Cir. 2004) he wrote: "The realistic alternative to a class action is not 17 million individual suits, but zero individual suits, as only a lunatic or a fanatic sues for $30."

A seven-hundred-dollar supplement dispute or a two-thousand-dollar valuation shortfall is the ordinary shape of a collision claim. Three mechanisms have bridged the gap between a right and a lawyer: fee shifting, assignment to a repeat player, and the class action. Florida narrowed all three in a single legislative window.

Assignment went first for auto glass. CS/SB 1002 (2023), chapter 2023-136, effective May 25, 2023, creates section 627.7289, Florida Statutes, "prohibiting persons from entering into assignment agreements of post-loss benefits for motor vehicle glass replacement or repair after a specified date; providing that such assignment agreements are void and unenforceable."

Then the fee statute. Section 11 of chapter 2023-15 reads, in its entirety: "Section 627.428, Florida Statutes, is repealed." Florida's one-way attorney fee provision is gone, and the Chapter 627 Part II index now runs from 627.427 directly to 627.429, with no entry in between.

The replacement closed the last door. Fla. Stat. 86.121, created by section 2 of chapter 2023-15, awards fees to a prevailing named insured, omnibus insured or named beneficiary in a declaratory action after a total coverage denial, and then says of that right: "This right may not be transferred to, assigned to, or acquired in any other manner by anyone other than a named or omnibus insured or a named beneficiary."

Abolishing the assignment removes the shop's standing. Making the fee right non-assignable removes the shop's economics even where standing somehow survives. One session, both halves.

Shield five: the record stays closed

If a case is dismissed on the pleadings there is no discovery at all. If discovery happens, Fed. R. Civ. P. 26(c)(1)(G) lets a court order "that a trade secret or other confidential research, development, or commercial information not be revealed or be revealed only in a specified way," and Seattle Times Co. v. Rhinehart, 467 U.S. 20 (1984) holds unanimously that such an order "does not offend the First Amendment," because "A litigant has no First Amendment right of access to information made available only for purposes of trying his suit."

The best-known example cuts both ways, and is usually told backwards. In Allstate Floridian Insurance Co. v. Office of Insurance Regulation, 981 So. 2d 617, decided by Florida's First District Court of Appeal on May 14, 2008, the court affirmed an immediate final order suspending Allstate's certificates of authority to transact new insurance business in Florida. The suspension "would terminate upon Allstate producing documents OIR previously subpoenaed in an investigation of Allstate's insurance practices." Allstate "had labeled every one of the approximately 30,000 documents it had produced as 'trade secret.'" Asked whether it was prepared to produce "the McKinsey documents," its counsel answered "subject to the appropriate protections . . . privileges." The order under review rested in part on a report by J. Robert Hunter which, as the court summarized it, alleged that Allstate used a computer program "designed to systematically reduce payments to policyholders without adequately examining the validity of each individual claim." That is an allegation in that report, not a finding by the court. Meanwhile Allstate was "held in contempt of court in Missouri with a $25,000.00 per day fine," fines that by the hearing date "exceeded $2 million." The court's answer to the blanket designation was flat: "Nothing prevented Allstate from timely filing a privilege log and seeking a protective order in circuit court, specifically identifying any of the requested documents they believed were privileged."

So the designation lost. But look at who beat it: a state regulator holding subpoena power and the authority to suspend a certificate of authority. A private litigant has neither and cannot generate either. And look at what the regulator was up against, in the court's own words: "Allstate's representations that it would decide which documents it would produce, and Allstate's history of incurring millions of dollars in court-ordered fines rather than comply with court-ordered production."

The forum that publishes nothing

One more reason the public record looks thin: insurer-versus-insurer damage disputes run through a private forum in enormous volume, and none of those filings is a court case.

Arbitration Forums, Inc., headquartered in Tampa, was "[f]ounded by the insurance industry in 1943" and calls itself "the nation's largest arbitration and subrogation services provider." Its own account of 2025: "members filed 1.1 million arbitration disputes and 2.3 million subrogation demands collectively worth almost $27 billion in claims," across more than 5,100 member companies. Its programs include auto physical damage, personal injury protection and medical payment. Its arbitrators are not outsiders: it "utilizes a neutral panel of over 6,700 claims professionals from our member companies."

This is where insurer-versus-insurer auto damage questions go: who pays for the repair, on what methodology, with what parts, at what value. It runs on industry-drafted rules, before arbitrators drawn from the member carriers, and its arbitration forums sit in the private area of its own site, "accessible only to users who have been ... authorized on behalf of their organization." On the site's own account of who may enter that area, nothing in it is published to anyone outside the membership. Every question decided in that forum is one no court decided.

What worked, and why

One theory survived the whole apparatus, and it survived because it offers no surface for any of these shields to grip.

The en banc Eleventh Circuit affirmed dismissal of every aggregate theory in MDL 2557 and vacated dismissal only of tortious interference, which the district court had thrown out on group pleading. Its reasoning is the most useful passage in the litigation for anyone on the shop side:

"It is not the potential customer who is the target of the alleged tortious interference; it is the targeted Body Shop. ... On the other hand, each Insurance Company, or its claims adjusters, will know whether the company engages in such a practice, and will know whether each named Plaintiff in the five complaints was noncompliant with that company's preferred practices and, most important, whether its insureds were steered away from that Plaintiff Body Shop."

That is a holding about evidentiary asymmetry: the shop cannot know what it cannot see, and the defendant already does. Nothing comparable was extended to the antitrust claims in that opinion.

A year later, in Automotive Alignment, two tortious interference claims survived the pleading stage, both against Progressive, brought by AutoWorks Collision Specialist and Walkers Collision Center. What made them work was specificity plus the absence of any cost justification: Progressive "misleadingly told the customers that it would guarantee the repair work if they used Progressive's preferred shops, but not if they used Autoworks or Walkers," and Progressive "pays the same amount for repairs whether they are performed by a preferred or non-preferred shop." Steering that saves the insurer nothing cannot be explained as cost control.

The same opinion shows how narrow the path is. The group allegations failed as shotgun pleading. Of the fifteen individual instances of steering pleaded, ten failed on damages because the steering attempt was unsuccessful, and three of the five successful ones failed because malice was not alleged. Two were left. A district court, the panel noted, "is required to give a counseled plaintiff only one chance to replead before dismissing a complaint with prejudice on shotgun-pleading grounds."

Compare the requirements. A Sherman Act claim needs an agreement among defendants, a defined market, and a class to be worth bringing at all. A tortious interference claim needs one defendant, one plaintiff, one false statement and one lost job. No agreement to infer, so plausibility has nothing to bite on. No class, so predominance never arises. No rate, and no federal hook.

Take the hopeful reading with the sober one attached. We are not saying the shops ultimately won anything. Surviving a motion to dismiss is not winning, and what happened to these claims after remand is not established here. Every theory capable of reaching conduct at industry scale has been closed in the four opinions read here. The one left open reaches a single customer at a time, and Judge Posner's arithmetic applies to it too. This is not immunity. It is a remedy scaled below the conduct, which is more durable, because nobody has to defend it.

What we could not establish

Whether McCarran-Ferguson was ever pleaded in MDL 2557. Confirmed, by full-text search of the official Eleventh Circuit slip opinions: the words "McCarran" and "Ferguson" appear in none of the four, and neither does "exemption," "immunity" or "business of insurance." The Act's only appearance in any of the four is the citation to 15 U.S.C. section 1013(b) described above, in the boycott discussion. The same search was run on the April 6, 2018 order vacating the panel opinion and taking the case en banc, with the same result. Not confirmed: what the defendants argued below. The district court orders were not obtained and the briefs were not read. The accurate statement is that these appellate opinions never name the Act and never apply an exemption, not that no defendant raised it.

Whether any court has applied the Pireno test to an insurer-repairer arrangement. The application here follows from the face of the test. No decision applying it to a body shop agreement was located. The point is untested and is offered as reasoning, not holding.

What happened to the remanded tortious interference claims. Tortious interference claims in five cases went back in March 2019, and two body shops' claims went back in March 2020. Whether any reached judgment, settled or was dismissed is unknown here, and that answer determines whether "tortious interference survived" means anything in practice. Nothing on this page should be read as saying the shops ultimately won anything.

Quotations. Every quotation above was checked character for character against an official court PDF, the United States Reports, the United States Code, or the issuing body's own document; passages that could not be reproduced from those sources were removed rather than published. What is genuinely absent from the Sos opinion is the word predominance and the word predominate, and so this page makes no claim about an extended predominance analysis there.

Numbers we did not publish. The Florida Bar's contingent-fee schedule was never obtained, so no percentage appears here. Settlement figures from earlier research, including nine-figure amounts attributed to several carriers, were not independently verified and are omitted. The sales tax and title transfer shortfall amounts in Sos came back differently from two retrievals and are not stated. Our earlier note put the Missouri contempt fines at roughly $2.4 million; the opinion says they "exceeded $2 million," and that is what appears above. Figures showing Florida glass suits rising into the tens of thousands come from tort-reform advocacy groups campaigning for the 2023 legislation, are not neutral, and are not repeated here.

Appraisal. Whether carriers have narrowed or removed appraisal clauses from private passenger auto policies is asserted often and is unsourced here. It is testable against policy form filings with state insurance departments, and we make no claim until that is done.

Scope. The standing discussion rests on the instruments quoted, California, Pennsylvania and Florida, plus the survey count inside Moradi-Shalal as that court reported it in 1988. It is not a fifty-state map. The six-circuit count is taken from the Sixth Circuit's own list of aligned decisions as of April 2026 and says nothing about state courts, which are not bound by Rule 23. The Arbitration Forums figures, including the claim to be the nation's largest such provider, are the organisation's own published numbers on its own site, reported by it and not independently audited. We are not claiming that its decisions are unobtainable outside its member portal; we could not establish whether they are obtainable by a shop, a consumer, a regulator or a researcher through any channel outside it, or whether any insurance department audits its outcomes for patterns. Sos v. State Farm is an unpublished Eleventh Circuit decision and is not binding precedent in that circuit.

Corrections

This page is new, and the entries below are corrections made to its own draft before publication, not corrections forced by a reader afterwards. They are published because a page that shows only its wins is not evidence of anything.

2026-09-01, the antitrust exemption claim in the headline argument. The draft said of the four Eleventh Circuit opinions: "None of them mentions McCarran-Ferguson." That is true only of the statute's popular name. Full-text search of the official slip opinions found that the 2017 panel and the 2019 en banc court each cite 15 U.S.C. section 1013(b), which is a codified section of that Act, and each pairs it with St. Paul Fire and Marine Insurance Co. v. Barry, the Supreme Court's case on the Act's boycott exception. The claim was narrowed to what the record supports, that not one of the four names the Act and not one applies an exemption, and the section 1013(b) finding was moved into the argument as affirmative evidence, because 1013(b) is the provision that withdraws the exemption for boycotts. This page's whole argument is that the received wisdom is wrong, and the draft was wrong in the same direction.

2026-09-01, two false disclaimers about missing quotations. The draft's disclosure section said that a Pireno phrase describing peer review as "ancillary to the claims adjustment process" could not be located in the opinion, and that a sentence in Sos did not appear in the official version checked. Both statements were wrong. Both passages are in the official opinions, and the earlier misses were instrument defects: a de-hyphenation rule in the string matcher joined words across line breaks, and page headers injected mid-sentence in Eleventh Circuit slip PDFs broke otherwise exact strings. The false disclaimers were removed, the two Pireno sentences were added to the argument where they strengthen it, and the surviving true half was kept, that predominance and predominate are genuinely absent from Sos.

2026-09-01, the Allstate Floridian paragraph. The draft stated an allegation as record fact, describing a withheld "consultant's report" that was a program "designed to systematically reduce payments to policyholders." The opinion attributes the allegation to a report by J. Robert Hunter, the quoted sentence describes a computer program rather than a report, the word consultant does not appear in the opinion, and the whole passage is an allegation before the regulator rather than a court finding. The paragraph now names Hunter, says "as the court summarized it, alleged," and says in the same breath that this is an allegation in that report and not a finding by the court. Two unsourced sentences claiming the tactic "bought years" and that the documents "stayed out of circulation throughout" were cut and replaced with the court's own description of what the regulator faced.

2026-09-01, three superlatives in our own voice. The draft called MDL 2557 "the largest body-shop antitrust case ever brought" and said total-loss valuation was now litigable "in most of the federal system," neither of which was established. They became "the multidistrict body-shop antitrust litigation" and "across six federal circuits," which is the Sixth Circuit's own count. The draft also asserted as fact that Arbitration Forums is the largest auto damage adjudication system in the United States; that is the organisation's marketing claim, it now appears only inside quotation marks as its self-description, and the section heading was changed accordingly.

2026-09-01, absolutes without boundaries. "In most states bad faith belongs to the insured" was not established for fifty states and became "where it exists it runs to the insured," carried by the instruments actually quoted. "A shop is never the insured" became "A repair shop is not the insured under its customer's policy," because a shop plainly holds its own policies. The equation of actual cash value with fair market value in Lara was scoped to Washington law, which is where the court found it.

2026-09-01, how the cases are cited. The 2017 panel opinion was printed without saying it had been vacated, so a reader could have cited it as live authority; the vacatur now sits in the same sentence as the holding. Sos is now identified as unpublished, and its "individualized damages calculations" line is attributed to Carriuolo v. General Motors Co., which is what the opinion does. The Clippinger class is 90,000, not "roughly 90,000," and the quoted phrase was corrected to the opinion's plural. Links to three of the body shop opinions were moved off an aggregator's lead-docket slug and onto the court's own PDFs, with the real docket numbers printed.

Related

Sources

Every quotation on this page was re-pulled from its primary source and string matched against the official text before publication, with a control string that cannot appear in the document included in each batch so that a false miss would show itself. Anything that would not re-verify was cut rather than softened, and what was cut is listed above under what we could not establish and under Corrections. The court PDFs were downloaded from the issuing courts' own servers and read on 2026-09-01; the statutes, the rules and the model law were read on 2026-09-01 from the enacting body's own published text; the Arbitration Forums figures were read on 2026-09-01 from that organisation's own pages. This page describes published law and public records and is not legal advice.

Two kinds of wall are worth naming, because they shape how this page cites things. Justia, the court-opinion aggregator behind the Royal Drug, Pireno, Seattle Times, Moradi-Shalal and Allstate Floridian links above, refuses automated readers: it returns 403 to a scripted client and 200 to a browser, which is bot protection rather than a dead link, and each of those links resolves in a browser to the case named. CourtListener's citation lookup separately returned 404 for three of the reporter citations that appear verbatim inside the Sixth Circuit's own opinion, which is an indexing gap and not evidence that a citation is wrong. Because a database that will not answer a machine cannot settle a citation, the four body shop opinions here are cited by name, court, docket and date, no reporter citation is printed for them, and the five reporter citations that are printed were taken from the face of the Clippinger opinion itself. The research container's own egress proxy also refused every one of these hosts, so the verification pass was run from a machine with unrestricted egress rather than through any summarising retrieval layer.

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