How Motor Vehicle Repair Shops Can Protect Against “Unauthorized Work” Claims

By Brian M. Gibbons on October 20, 2026

Motor vehicle mechanics may consider it common sense to obtain authorization from a customer before undertaking repair work on the customer’s vehicle. But the specific laws regarding motor vehicle repair authorizations, and the potential consequences of not documenting authorization to commence work, may not be as widely understood or appreciated.

Adler Pollock & Sheehan represents dealerships and motor vehicle mechanics in Massachusetts, Rhode Island, and Connecticut. All three of these jurisdictions have similar laws requiring authorization.

Connecticut

Connecticut General Statutes § 14-65f states: “Prior to performing any repair work on a motor vehicle, a motor vehicle repair shop shall obtain a written authorization to perform the work, on an invoice signed by the customer, that includes an estimate in writing of the maximum cost to the customer of the parts and labor necessary for the specific job authorized.”

This statute includes an exception that authorization may be given orally “[i]f a motor vehicle is delivered to a repair shop at a time when the shop is not open for business” – for example, if a customer brings a vehicle to the shop after hours. Somewhat confusingly, the statute also allows a repair shop to charge for work without a written authorization if the customer gives consent orally. The statute is so confusingly worded that multiple Connecticut Superior Court judges have interpreted the requirements differently from one another, as discussed in

Zwerdling v. Broadbridge Auto. Servs., Inc., No. CV196087779S, 2020 WL 3058146, at *4 (Conn. Super. Ct. May 11, 2020).

Basically, the statute permits oral authorization in some circumstances but strongly encourages written authorization. In the event of a dispute, it is of course much easier for a shop to produce evidence of written authorization rather than assert that oral authorization was given, which the customer could easily deny.

Violation of this section is an infraction that can result in civil penalties imposed by the Commissioner of the Department of Motor Vehicles. Beyond civil penalties, however, there can be other consequences that are harder to foresee. If a customer does not provide written authorization and then refuses to pay for the work, it will be nearly impossible for the shop to recover from the customer.

In Torrington Diesel Corp. v. Weingart Custom Bldg. & Remodeling, Inc., No. LLICV156011965S, 2016 WL 572387, at *5 (Conn. Super. Ct. Jan. 20, 2016), a customer refused to pay for over $6,000 of repairs to a dump truck. Even though the customer and shop had a history of prior dealings, as a matter of law, the shop could never succeed on an action to collect for services rendered without a signed a written authorization prior to the work being performed. Torrington Diesel Corp. v. Weingart Custom Bldg. & Remodeling, Inc., No. LLICV156011965S, 2016 WL 572387, at *5 (Conn. Super. Ct. Jan. 20, 2016).

Connecticut courts have also held that failure to obtain written authorization constitutes unfair trade practices in violation of the Connecticut Unfair Trade Practices Act (CUTPA). Zwerdling v. Broadbridge Auto. Servs., Inc., supra, No. CV196087779S, 2020 WL 3058146, at *4.

Massachusetts

Massachusetts Regulations provide that it is an unfair or deceptive act (and therefore a Chapter 93A violation) for a repair shop to charge for repairs unless the shop has received written authorization signed by the customer. There is an exception “[i]f the repair shop is unable to obtain written authorization from the customer to perform specific repairs (as when the specific repairs to be performed on the vehicle are not known at the time the vehicle is delivered to the repair shop).” Failure to do so is a regulatory violation, though in a civil action alleging failure to follow this statute, the customer must still prove harm. See LimoLiner, Inc. v. Dattco, Inc., 919 F.3d 86, 91 (1st Cir. 2019) (finding a regulatory violation but requiring proof that violation caused injury).

In Com. v. Swan, 38 Mass. App. Ct. 539, 543 (1995), the lack of written authorization even presented a defense to a criminal larceny charge against a customer for stopping payment on a check to a repair shop.

Rhode Island

5 R.I. Gen. Laws § 5-38.3-3 requires a work order documenting authorization by a customer for repair work. The work order can be written or oral, but a work order given orally “shall be noted on the invoice and shall include the date, time, and manner of authorization and by whom the authorization was given.” Violations can result in civil penalties.

Practical tips

Obtaining customer authorization for repair work seems simple, but auto shops get busy, and customers often drop off vehicles after hours and then discuss repairs over the phone. In the event of a dispute, a signed authorization can make the difference between getting paid and defending a lawsuit and facing civil penalties. Auto shops should consider using Docusign or similar software to generate and send forms that their customers can sign digitally from their smartphones, to minimize the risk of a missed signature.