Reinforcing Federal Court Discretion Under the Declaratory Judgment Act in the Face of Conclusory Pleadings and Parallel State Proceedings
Commentary on Michael Miller v. County of Lancaster, No. 24-2934 (3d Cir. July 28, 2025)

1. Introduction

In Michael Miller v. County of Lancaster, the United States Court of Appeals for the Third Circuit affirmed a district court’s dismissal of a pro se plaintiff’s federal action seeking declaratory and injunctive relief concerning public access to Pennsylvania election records. The decision—though expressly “Not Precedential”—clarifies the breadth of a district court’s discretion to decline jurisdiction under the Declaratory Judgment Act when: (1) the plaintiff’s federal claims are pled in a vague, conclusory manner, and (2) substantially related or “parallel” state proceedings are already under way. It also illustrates how venue considerations and comity principles can converge to justify dismissal rather than transfer or abstention.

2. Summary of the Judgment

The Third Circuit panel (Judges Krause, Phipps, and Scirica) held:

• The district court did not abuse its discretion in declining to issue a declaratory judgment because the Reifer/Kelly factors weighed against entertaining the suit.
• Miller’s concurrent appeals in Pennsylvania Commonwealth Court qualified as “parallel state proceedings,” further supporting dismissal.
• Any alleged error in the district court’s standard of review (clear-error vs. de novo) was harmless because the appellate court examined the issue de novo and reached the same conclusion.
• Claims for injunctive relief and constitutional challenges failed because they were “wholly vague and conclusory” and, in some instances, sought remedies (e.g., rewriting state statutes) beyond federal power.
• All outstanding motions by Miller, including requests for summary reversal, were denied.

3. Analysis

3.1 Precedents Cited and Their Influence

• Reifer v. Westport Insurance Corp., 751 F.3d 129 (3d Cir. 2014) – Provided the multi-factor test for deciding whether to hear a declaratory-judgment action. The district court, adopting the magistrate judge’s report, weighed these factors (e.g., pending state proceedings, convenience, public interest) and chose dismissal.
• Kelly v. Maxum Specialty Insurance Group, 868 F.3d 274 (3d Cir. 2017) – Clarified appellate review standards (abuse of discretion for dismissal; de novo for legal errors) and refined the concept of “parallel state proceedings.” The Third Circuit relied on Kelly to rebut Miller’s argument that his state case was not parallel.
• Rarick v. Federated Service Insurance Co., 852 F.3d 223 (3d Cir. 2017) – Stands for the proposition that when coercive relief is sought in addition to declaratory relief, a court cannot dodge jurisdiction simply by labeling the case “declaratory.” Although the panel acknowledged Rarick, it found Miller’s pleadings too conclusory to trigger mandatory jurisdiction.
• Ayotte v. Planned Parenthood of Northern New England, 546 U.S. 320 (2006) & Conchatta Inc. v. Miller, 458 F.3d 258 (3d Cir. 2006) – Cited for the proposition that federal courts cannot rewrite or “blue-pencil” state statutes, undercutting Miller’s request that the court craft “interim provisions” governing record access.
• Zwickler v. Koota, 389 U.S. 241 (1967) – Invoked by Miller to argue mandatory federal jurisdiction over federal questions. The panel distinguished Zwickler because it dealt with abstention, not the discretionary Declaratory Judgment Act.

3.2 The Court’s Legal Reasoning

1. Declaratory Judgment Act Discretion
   • Unlike ordinary federal-question jurisdiction (28 U.S.C. § 1331), the Declaratory Judgment Act (28 U.S.C. § 2201) confers discretion on federal courts—it “created an opportunity, not a duty.”
   • Applying Reifer, the court weighed (a) the state’s strong interest in election administration; (b) ongoing state-court review of the same county determinations; (c) the federal court’s interest in avoiding piecemeal litigation; and (d) the plaintiff’s vague pleadings. Each factor pointed toward dismissal.
2. Existence of Parallel State Proceedings
   • Miller argued that his Commonwealth Court cases were not parallel because they lacked his federal claims. The panel disagreed, noting that he had, in fact, raised constitutional issues in those appeals.
   • Even if federal claims were imperfectly pled in state court, the proceedings were still “substantially similar” because they revolved around the same records, the same legal barriers, and the same requested relief.
3. Insufficiency of the Pleadings
   • Federal courts cannot issue advisory opinions. Vague rhetorical questions (e.g., “Does the County’s imposition of restraints prevent free and general discussion of public matters?”) fail to set forth a concrete controversy.
   • Lack of factual detail also doomed Miller’s requests for coercive (injunctive) relief, because Rule 8(a) requires a “short and plain statement” articulating entitlement to relief.
4. Venue and Convenience
   • The magistrate judge alternatively recommended transfer to the Eastern District of Pennsylvania, where the county sits. Ultimately, because Miller had already filed a parallel action there, dismissal was deemed the cleaner solution.

3.3 Potential Impact of the Judgment

Although non-precedential, the decision carries persuasive weight within the Third Circuit and offers guidance nationwide in three principal areas:

• Litigant Strategy – Plaintiffs seeking federal review of state-election record disputes must plead specific constitutional violations and avoid duplicative litigation in state court.
• Judicial Economy – District courts may confidently invoke Reifer/Kelly factors to streamline overloaded dockets when faced with conclusory Declaratory Judgment Act complaints.
• Transparency Litigation – Advocates of election transparency now have clearer signals that federal forums will be cautious about second-guessing state-level Right-to-Know-Law disputes unless plaintiffs articulate concrete federal harms.

4. Complex Concepts Simplified

• Declaratory Judgment Act (DJA) – A federal statute allowing courts to declare parties’ rights without ordering action. It is discretionary, meaning courts may decline to issue such declarations.
• Parallel State Proceedings – A concept from DJA jurisprudence asking whether another case in state court addresses substantially the same parties, facts, and issues. If so, federal courts often step back.
• Abuse of Discretion – The deferential standard appellate courts apply when reviewing a lower court’s discretionary decisions. The question is not whether the appellate judges agree, but whether the lower court’s choice was unreasonable or based on an erroneous legal view.
• Conclusory Pleadings – Allegations that state legal conclusions without concrete supporting facts. Courts may dismiss such pleadings under Rule 12(b)(6) or, as here, decline declaratory relief.
• “Blue-Penciling” Statutes – When a court rewrites or trims a statute to save it from invalidity. Federal courts are reluctant to perform this legislative function unless mandated by severability principles.

5. Conclusion

Michael Miller v. County of Lancaster is a primer on the wide-ranging discretion federal courts possess under the Declaratory Judgment Act, especially when: (i) the pleadings fail to present concrete, well-developed constitutional questions, and (ii) substantially similar litigation is ongoing in state courts. The Third Circuit’s affirmance underscores practical lessons for litigants: articulate precise constitutional harms, choose the proper forum, and avoid duplicative litigation. For courts, the opinion reaffirms that declining jurisdiction can be an efficient, legally sound path when federal intervention would interfere with state processes or yield only advisory pronouncements. While non-precedential, the case is likely to be cited by practitioners and judges confronting the intersection of election-transparency disputes, Right-to-Know Laws, and federal declaratory-judgment practice.