I did not specify a maximum # of galleries per user. This caused imce_gallery to respond with the 'Maximum gallery reached' message. I wandered through the code and found the culprit.

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#1 imce_gallery_0.patch739 bytesphoolish
imce_gallery.patch992 bytesphoolish

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phoolish commented
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new imce_gallery_0.patch739 bytes

Whoops... removed a check I added.