Freeland v. Liberty Mutual Fire. Ins. Co., 632 F.3d 250, 252-253 (6th Cir. 2011). Judge Amul Thapar explained in Freeland: "The amount in controversy in this declaratory judgment action is exactly one penny short of the jurisdictional minimum of the federal courts."
Singer v. State Farm Mut. Ins. Co., 116 F.3d 373, 375 (9th Cir. 1997). The court explained: "The parties to this case were caught between the California statute prohibiting statement of an ad damnum, and the traditional federal removal framework, which bases removal on the amount stated in the ad damnum."