CARFAX isn't and won't be liable for anything. They can only show what is reported, either through insurance companies or police reports. I had $8,000 in damage to an old M3 and it never showed up on the CARFAX. CARFAX is definitely only one necessary step in researching a potential car purchase. They advertise the "buy back" clause but I highly doubt they even pay out on an inaccurate report. That's what high dollar corporate lawyers are for.

You do not have any recourse with the dealer unless your communications were written, and even then I doubt you would be able to recoup any costs. You would end up spending more money in court costs and attorney's fees than you would pocket in the end - and that's if you won.

Many used car dealers know absolutely nothing about the cars they are selling, and know even less about body work. There is a good chance the person that sold you the car had no idea of the previous bodywork. I would send him a firmly worded letter with a copy of the work being done and explain that he might want to represent his vehicles better in the future. You can also file a claim with the BBB and see if he responds.

Bottom Line - Never buy a car without a pre-purchase inspection. More so with high-end vehicles, and even more so when buying site unseen.

Chalk this one up to a bad experience and just learn from your mistake