How serious a level of damage before it refuses -y?
Just guessing, but probably anytime 2 or more concurrent writes had allocated space but not completed the updates.
I cannot remember any time that I have not been able to do -y and there have been times when I saw a huge amount of errors being automatically fixed.
With ext2 my odds were at least one out of 10 that a busy machine wouldn't come back up automatically after a power glitch. Ext3 is much better because it normally just uses the journal to recover.
Hang on, I might be off on a tangent here. Are you saying there is a difference between fsck on ext2 and fsck on ext3 (when not doing journal recovery of course) when it comes to -y?