A New Jersey federal court has abstained from exercising jurisdiction over a removed insurance coverage declaratory judgment action where the underlying action was ongoing in state court. Owen v. Hartford Ins. Co., 2014 WL 2737842 (D.N.J. June 17, 2014).  The court did so because the underlying action could have been consolidated with the coverage action, even though the insured had not yet moved to consolidate the two actions at the time of removal.  The opinion can be found here.

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