AA SUNCOAST CHIROPRACTIC CLINIC, P.A.
v.
PROGRESSIVE AMERICAN INSURANCE COMPANY

11th Cir. | 2019-09-12
No. 17-13003
938 F.3d 1170 Court of Appeals for the Eleventh Circuit (2019) Caution
Cited by 14 cases

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Headnotes

[1] Injunctive relief under Federal Rule of Civil Procedure 23(b)(2) is inappropriate when the requested relief is primarily retrospective and seeks to redress past harms rat…

[2] Declaratory relief, like injunctive relief, requires a likelihood of future harm to establish Article III standing.

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Opinion of the Court

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Cited By

  • Mack v. USAA Cas. Ins. Co., 994 F.3d 1353 (11th Cir. 2021)
    …to sue for a declaratory judgment about the method it uses to assess payments under the policy. To argue for a contrary result, USAA relies on this Court's analysis in AA Suncoast Chiropractic Clinic, P.A. v. Progressive American Insurance Company, 938 F.3d 1170 (11th Cir. 2019). The question in AA Suncoast was whether the district court had erred in certifying an injunction class under Federal Rule of Civil Procedure 23(b)(2). See AA Suncoast, 938 F.3d at 1172. A class action may be maintained under Rule 2…
  • Anderson v. Wilco Life Ins. Co., 943 F.3d 917 (11th Cir. 2019)
    …tiff's requested injunctive relief was "an injunction against continuing violations of Florida law”—which this Court called a “tag-along prayer for injunction." Id. at 1358; see also AA Suncoast Chiropractic Clinic, P.A. v. Progressive Am. Ins. Co., 938 F.3d 1170, 1175–79 (11th Cir. 2019) (concluding that the injunction requested by a class action plaintiff was merely a de minimis request and the class action was all about obtaining money damages for past injuries). In stark contrast, Anderson's injunctive d…
  • …laintiff is seeking injunctive or declaratory relief, a plaintiff must allege facts from which it appears there is a substantial likelihood that he will suffer injury in the future." AA Suncoast Chiropractic Clinic, P.A. v. Progressive Am. Ins. Co., 938 F.3d 1170, 1179 (11th Cir. 2019) (quotation omitted). The Eleventh Circuit "has acknowledged the plaintiff's need to show the likelihood of injury as a prerequisite for standing to obtain equitable relief," Cone Corp. v. Fla. Dep't of Transp., 921 F.2d 1190,…

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