Only experience I had with a goodwill repair was way out of warranty for a non-safety item(stuck exterior door handle) so they definitely aren't limited to warranty or lemon issues.
Note: this was just staying with the theme of the article and not that I agree with the accusations.
I took an out of warranty Honda Accord in for service at a Dealership and they discovered a cracked engine block. They performed a goodwill repair under the auspices that "that shouldn't happen".