No, and no. What damages could the plaintiff have shown here? He got his money back, and Tesla kept the car. He had never executed a bill of sale for the car.

No, and no. What damages could the plaintiff have shown here? He got his money back, and Tesla kept the car. He had never executed a bill of sale for the car. While what Tesla did looks like horrible customer service, there was no damage here, any more than when you order the daily special at a restaurant and the waiter comes out to tell you it's sold out. As for libel, if he is telling the truth, then in the US, it can not be libelous. The saying goes "truth is an absolute defense against libel" IANAL ...