"Thus, as a general rule, the district court may not consider the merits of the declaratory judgment action when 1) a declaratory defendant has previously filed a cause of action in state court against the declaratory plaintiff, 2) the state case involves the same issues as those involved in the federal case, and 3) the district court is prohibited from enjoining the state …

Any doubts as to the propriety of an injunction must be resolved in favor of allowing the state court action to go forward.

Moreover, we will not recharacterize the state-law claims asserted by the real parties in interest as federal claims.

—the defendant filed a suit in a Texas state court against his employer's compensation carrier for mental anguish following the carrier's delay

Other parties have tried this ruse, and most courts that have addressed this issue have rejected their argument.

—if the Anti-Injunction Act bars a federal court from issuing an injunction, the issuance of a declaratory judgment that would have the same effect is also barred.

—holding that § 2283 must not be reduced to "an anachronistic, minor technicality, easily avoided by mere nomenclature or procedural sleight of hand

By generally barring such intervention, the Act forestalls “the inevitable friction between the state and federal courts that ensues from the injunction of state judicial proceedings by a federal court.”

[BOOK] Moore's federal practice

[PDF] United States District Court Eastern District of Louisiana

[CITATION] Missouri Law Review