Can a claim for declaratory relief be used to circumvent partial adjudication of a cause of action for breach of contract?

Although summary adjudication on declaratory relief claims may be granted in the pronouncement of contractual duties, a claim for declaratory relief may not be employed to circumvent the rule against partial adjudication of a cause of action for breach of contract. (Hood v. Superior Court (1995) 33 Cal.App.4th 319 (Hood).) In Hood, an insurer sued its former agent for breach of a noncompetition agreement, asserting various causes of action premised on violation of the agreement. (Id. at p. 322.) The agent filed a cross-complaint alleging breach of contract and several tort causes of action. (Ibid.) The insurer responded by moving for summary adjudication of the agent's breach of contract cross-claim. The trial court denied the motion on the ground that it did not dispose of any action in the cross-complaint. (Ibid.) The insurer amended its complaint to state a cause of action for declaratory relief to the effect that the agent had breached the noncompetition agreement. The insurer then moved for summary adjudication on

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