Sounds like a great "excuse" for the dealership to use. Simply add a quart or oil, or three, and suddenly it becomes the customers problem. With most people not changing their own oil anymore, its a pretty easy scam to pull off.
That is one reason I only use the dealer for oil changes while under warranty. If they are the only ones that touched it, then it's their problem with certainty. Had one come back to me and say the drain plug was stripped. I told them to check the records. No apology, but no charge either.
