# Opinion

> District Court, M.D. Florida · May 29, 2026

URL: https://www.frixlaw.com/law-library/cases/11370017

## Case

- **Full name:** Jeremiah Williams v. Regal Palms Owners’ Association, Inc.
- **Court:** District Court, M.D. Florida
- **Decided:** May 29, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11370017. Public record. Not legal advice.
