The following excerpt is from Budget Rent-A-Car v. Crawford, 108 F.3d 1075 (9th Cir. 1997):
Wilton teaches us that before exercising its discretionary jurisdiction under the Declaratory Judgment Act, a district court must consider whether a related state court action was filed after federal declaratory relief was requested. We are persuaded that the same federalism concerns against the use of the Declaratory Judgment Act as a forum shopping device, and the policy against "having federal courts needlessly determine issues of state law," Chamberlain v. Allstate Ins. Co., 931 F.2d 1361, 1367 (9th Cir.1991), are also present when a federal plaintiff seeks declaratory relief in anticipation that a related state court proceeding may be filed.
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