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I'm not sure about leasing, but when I bought my 2018 Volt I got it with 2400 miles on it at the dealership and it hadn't been titled. The dealer only used Volts as their courtesy cars and after three months or 3,000 miles they took them out of service, took the full 7,500 tax credit on them and put them up for sale. I ended up getting Ruby for over 12K less than the sticker price (along with zero percent financing) and all but 3 months of the full warranty.
I couldn't have afforded the Volt otherwise, and I couldn't have gotten the full 7,500 dollar tax credit if I bought it with zero miles, so it worked out well!
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