The Illinois Automotive Repair Act requires a written estimate before repairs are performed. Exceptions apply for (1) Commercial fleet repairs and (2) ongoing service or maintenance. The Customer may also sign a written waiver agreeing that an estimate is not required. The Illinois Appellate Court recently ruled that it is not necessary to prove that the repair shop knew of the Statute. It is only necessary to prove that the repair shop acted intentionally, and the mechanic's statement that he was too busy to provide an estimate before performing $9,000 worth of repairs meets the requirementy of intentional conduct. A violation of the Automotive Repair Act also constitutes a violation of the Illinois Consumer Fraud Act, permitting awards for Attorneys Fees and Punitive Damages. Bell v. Ring. ( Ill. App. 3d dist, Sept. 2018).