Car has odometer roll back

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My cousin bought a car off a Craigslist ad. The car is a 1999 Toyota with an advertised 120k miles on the car, and the seller stated it as such. He purchased the car, and later found out that the Carfax showed that the car has over 275k miles on it after he had done some repairs. Also, the title was not in the seller's name and it looks like the seller just did a quick flip without registering the car in his name. The seller also filled in the sale price as $500. Initially, the seller agreed to take the car back and return his money, but requested to give him some time to gather it. This continued for two weeks and then he decided to stop answering his phone calls and messages.

Is my cousin out of luck on this one or can he file a small claims case?
 
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