Estimating Amount In Controversy Not 'Nuclear Science'

Law360, New York (March 21, 2014, 2:16 PM EDT) -- Answering a question left undecided in other circuits, the Eleventh Circuit held in South Florida Wellness Inc. v. Allstate Insurance Co., No. 14-10001 (Feb. 14, 2014) that a complaint seeking only declaratory relief “can be up to the task” of satisfying the Class Action Fairness Act’s $5 million amount-in-controversy requirement.

In an alleged class action filed in Florida state court, South Florida Wellness claimed that Allstate underpaid it for treatment provided to a patient who Allstate insured under a personal-injury-protection (PIP) policy. Rather than paying 80...
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