Williamson v. Farrell, 2019 UT App 123 (July 18, 2019)

The plaintiffs filed this action seeking a judicial declaration they had not committed elder abuse or breached any fiduciary duties to the husband’s elderly mother, as his siblings had publicly accused them of doing.  The district court dismissed the case on the basis there was litigation pending between the parties elsewhere, and the dispute could more effectively be litigated there.  The court of appeals reversed, holding that under the Declaratory Judgments Act, a court may only decline to hear an otherwise proper declaratory judgment action where entry of the sought-after declaration would not end the controversy giving rise to the specific lawsuit pending before them.  In this case, the district court had taken an overly broad view of this exception, reading it as applying if the declaratory judgment action would not terminate all the underlying disputes encircling the parties.