“As it turned out, the Model 3 had been declared a total loss last year after suffering extensive front-end damage. It was later sold on an auto auction website where it was listed with an estimated repair cost of $34,000. Yet despite this, the Model 3 still had its original title, and it was not branded as salvaged when Jackson purchased it.”
From the same article: Texas law has a 100% “total loss threshold,” which meant that unless a vehicle’s repair cost is more than what the car is worth, the title would remain original.