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Or if FedEx can produce an audit trail indicating the odometers were faulty and had been replaced. A vehicle with 400,000 miles has seen a lot. If the dash gauges were replaced around 220,000 miles, then 180,000 miles have passed since then - and the new odometer will read 180,000.

It is normal practice to replace a broken odometer with a new one. That is not fraudulent. However, when that vehicle is sold the seller is legally required to flag the title.

A lot of liability depends on why the odometer was replaced, who transferred the title (does FedEx transfer the title to Holman before sending the vehicle to auction, or does Holman hold the title the entire time?), and whether the title was appropriately flagged as "Not actual mileage".