Leroy Mack v. USAA Casualty Insurance Company, 994 F.3d 1353

Mack totaled his car; USAA paid “actual cash value” using the CCC ONE valuation system and Mack cashed the check.
Two months later Mack demanded additional amounts (title, license, and dealer fees); USAA said it was only responsible for actual cash value and tax.
Mack filed a state-court class action seeking declaratory judgments that USAA’s CCC ONE method and refusal to pay dealer fees violated Florida law and the policy, plus supplemental relief ordering recalculation and new offers to class members.
USAA removed under CAFA, invoked appraisal provision, and the district court dismissed the suit without prejudice pending appraisal; Mack appealed.
After settlement on title/license fee damages, only declaratory claims and supplemental relief (recalculation and dealer-fee offers) remained; Mack conceded recalculation might not increase offers.
The Eleventh Circuit held Mack lacks Article III standing to pursue declaratory relief (no substantial likelihood of future injury) and that the possibility of supplemental monetary relief does not alter the standing analysis; it vacated the dismissal and instructed remand to state court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to seek declaratory relief about USAA’s valuation method	Mack: his ongoing insurance relationship creates a present controversy and reasonable prospect of future total-loss injury supporting declaratory relief	USAA: future injury is speculative; plaintiffs lack substantial likelihood of future harm required for declaratory relief	Held: No standing — speculative possibility of another accident is insufficient (follows A&M Gerber and Malowney)
Whether request for supplemental monetary relief converts declaratory claim into retrospective damages (affecting standing)	Mack: declaratory relief may be followed by supplemental recalculation/offers; he framed claims as declaratory, not damages	USAA: supplemental relief shows true aim is monetary recovery for past losses, so standing for damages should be assessed	Held: Request for supplemental relief does not change standing analysis for declaratory claims; court must assess standing for the declaratory claim itself
Removal / disposition if federal court lacks jurisdiction	Mack: framed claims to avoid damages in federal court; removal is improper if no federal jurisdiction	USAA: removal was proper under CAFA; appraisal argument supported dismissal pending appraisal	Held: Because federal court lacks jurisdiction over the declaratory claims, district court must remand the unsettled claims to state court; dismissal vacated

Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (standing requires concrete and particularized injury)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III standing framework)
Malowney v. Fed. Collection Deposit Group, 193 F.3d 1342 (11th Cir. 1999) (declaratory relief requires substantial likelihood of future injury)
A&M Gerber Chiropractic LLC v. GEICO Gen. Ins. Co., 925 F.3d 1205 (11th Cir. 2019) (speculative chance of another accident is insufficient for declaratory-judgment standing)
AA Suncoast Chiropractic Clinic, P.A. v. Progressive Am. Ins. Co., 938 F.3d 1170 (11th Cir. 2019) (distinguishing injunctive relief that redresses past harms from relief preventing future injury)
Mills v. Foremost Ins. Co., 511 F.3d 1300 (11th Cir. 2008) (standing to pursue damages claims analyzed separately from standing for declaratory relief)
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are courts of limited jurisdiction)
Davis v. Fed. Election Comm’n, 554 U.S. 724 (2008) (party invoking federal jurisdiction must establish standing for each claim and form of relief)
Berger v. Xerox Corp. Ret. Income Guarantee Plan, 338 F.3d 755 (7th Cir. 2003) (declaratory judgments commonly precede other forms of relief)
Atlantic Marine Constr. Co. v. U.S. Dist. Ct. for the W. Dist. of Tex., 571 U.S. 49 (2013) (litigant may choose claims/venue to avoid certain courts)