It takes a hell of an accident to actually damage the battery pack to the point where physical damage can result in problems (short, fire, etc).
I've gotten cars that have been in rollovers, high speed collisions, and all sorts of accidents... and the vast majority had little to no damage done to the battery
case, let alone to the cells.
For example... this car literally was driven off a mountain, rolled multiple times:
(The battery from this car was pulled, tested, and used in another vehicle with zero issues.)
In any case, physical damage in an accident has absolutely nothing to do with this thread (loss of range due to Tesla's updates).