Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION

JEREMIAH WILLIAMS,

Plaintiff,

v. Case No. 8:26-cv-1441-KKM-CPT

REGAL PALMS OWNERS’

ASSOCIATION, INC.,

Defendant.

____________________________________

ORDER

Pro se plaintiff Jeremiah Williams sues Regal Palms Owners’

Association, Inc., for breach of contract, trespass to chattels, and a declaratory

judgment (complete with injunctive relief) that Regal Palms cannot continue

to “obstruct[] federally regulated mail delivery.” See Compl. (Doc. 1) ¶¶ 22–25,

29–33. Williams also attempts to bring a claim for “equitable relief” against

Regal Palms. See id. ¶¶ 26–28.

Williams’s dispute with Regal Palms arises from the latter’s refusal to

accept mail on Williams’s behalf. The United States Postal Service delivers

mail in the Regal Palms residential community only to the Regal Palms

clubhouse as it is the “mandatory centralized delivery point for all mail.” See

id. ¶¶ 11–12. In January 2024, after Williams’s failed to pay certain

assessments, the board of directors of Regal Palms suspended his voting rights

and his rights to use the common amenities, which includes the centralized

mail delivery at the clubhouse. See id. at 17. Thus, Regal Palms stopped

accepting mail on Williams’s behalf and returns all mail addressed to him as

“marked undeliverable.” See id.

Williams’s complaint avers that I have jurisdiction under 28 U.S.C.

§ 1331 and 28 U.S.C. § 1339. Id. ¶ 1. The former provides “original jurisdiction

of all civil actions arising under the Constitution, laws, or treaties of the United

States.” 28 U.S.C. § 1331. The latter gives “original jurisdiction of any civil

action arising under any Act of Congress relating to the postal service.” Id.

§ 1339. The complaint further contends that the action “arises under the

Supremacy Clause . . . and the Postal Reorganization Act (39 U.S.C. § 101 et

seq.).” Compl. ¶ 2. Lastly, there is allegedly supplemental jurisdiction over the

state law claims. Id. ¶ 6.

Williams began this action on May 13, 2026. On May 14, 2026, I directed

him to establish how subject matter jurisdiction exists over his action. (Doc. 8).

Williams responds to that order. Resp. (Doc. 12).

In response, Williams admits that he does not have a federal cause of

action, and that 39 U.S.C. § 101 does not create one. Id. at 1. Instead, he argues

that this action “ ‘arises under’ federal laws relating to the postal service,

satisfying the jurisdictional prerequisites of both § 1339 and § 1331.” Id. at 2.

Because federal regulations play a role in establishing and controlling the

delivery of mail and Regal Palms’s policy “disrupt[s] the transmission” of the

mail, which “threatens” Williams’s “ability to timely receive critical notices,”

this action purportedly arises under federal law. See id. at 2–3. In support,

Williams cites only Grable & Sons Metal Products, Inc. v. Darue Engineering

& Manufacturing, 545 U.S. 308 (2005). See Resp. at 4.

Grable recognizes that, in rare instances, a state law claim that

implicates federal issues can create federal jurisdiction. Grable, 545 U.S. at

312. This path to federal jurisdiction is incredibly narrow. See AST & Sci. LLC

v. Delclaux Partners SA, 143 F.4th 1249, 1252–53 (11th Cir.), cert. denied, 146

S. Ct. 370 (2025). Under Grable, “federal jurisdiction over a state law claim

will lie if a federal issue is: (1) necessarily raised, (2) actually disputed, (3)

substantial, and (4) capable of resolution in federal court without disrupting

the federal-state balance approved by Congress.” Gunn v. Minton, 568 U.S.

251, 258 (2013).

Williams’s action does not fit within the Grable framework. His contract

and trespass to chattels claims do not raise a federal issue. Whether Regal

Palms’s actions violate their contractual obligations towards members such as

Williams does not require the resolution of any federal issue. Compare id. at

259 (finding that a federal issue was necessarily raised when resolving a state

law legal malpractice claim would “require application of patent law to the

facts of [the] case”). Nor does determining whether holding and returning the

mail constitutes trespass to chattels under Florida law.

Williams does not otherwise identify an actual cause of action or an

appropriate basis to invoke a federal court’s jurisdiction and equitable power.

See McKinnon v. Talladega County, 745 F.2d 1360, 1362 (11th Cir. 1984)

(describing declaratory and injunctive relief as “prospective remedies”); Bey v.

Glass, No. 8:25-CV-01977-WFJ-CPT, 2025 WL 3442739, at *2 (M.D. Fla. Dec.

1, 2025) (“Declaratory judgments and injunctions, however, are not causes of

action. Instead, they are remedies tied to some other cause of action.” (citations

omitted)); cf. Samuel L. Bray & Paul B. Miller, Getting Into Equity, 97 NOTRE

DAME L. REV. 1763 (2022). Rather, Williams seeks to convert 39 U.S.C. § 101

into a private cause of action despite his claims to the contrary. See Resp. at 1;

id. at 4 (citing Grable). His declaratory judgment claim relies on allegations

that Regal Palms is “obstructing” the “federal postal scheme governed by 39

U.S.C. § 101.” See Compl. ¶¶ 22–25. There is no private cause of action under

§ 101. The statute, at most, imposes duties only on the Postal Service and

nothing indicates that private parties may sue to enforce the statute at all,

much less against another private party. See 39 U.S.C. § 101; see also Lundt v.

Hodges, 627 F. Supp. 373, 375 (N.D. Iowa 1985) (“Plaintiff also alleges a claim

under 39 U.S.C. § 101, et seq., against [the defendant]. The Court finds that

the complaint on its face fails to allege a claim upon which relief can be granted

in that it is based on the Postal Reorganization Act, which gives plaintiff no

cause of action.”); Shed v. Univ. of S. Fla. Bd. of Trs., No. 8:22-CV-1327-KKM-

TGW, 2023 WL 4420238, at *6 (M.D. Fla. July 10, 2023) (“Although federal law

makes it a crime to tamper with the mail, it provides no private cause of action

for mail tampering.” (collecting cases)).

Thus, despite Williams’s arguments, I lack subject matter jurisdiction

over his action and dismiss it without prejudice so that he may file it in state

court where it properly lies. In his response to my order, Williams requests

leave to amend the complaint to more “specifically articulate[]” the

jurisdictional basis for his claims. He provides no further information as to how

he would amend the complaint and cure the jurisdictional issues. Given the

lack of explanation, I decline.

Accordingly, the following is ORDERED:

1. This action is DISMISSED without prejudice for lack of subject

matter jurisdiction.

2. The Clerk is directed to ENTER JUDGMENT, which shall read,

“This case is dismissed without prejudice.”

3. The Clerk is further directed to TERMINATE all deadlines, pending

motions, and hearings, and to CLOSE this case.

ORDERED in Tampa, Florida, on May 29, 2026.

ae 4 Mizelle

United States District Judge