The following excerpt is from Guidry v. Durkin, 834 F.2d 1465 (9th Cir. 1987):
[T]he presumption of concurrent [state court] jurisdiction can be rebutted by an explicit statutory directive, by unmistakable implication from legislative history, or by a clear incompatibility between state-court jurisdiction and federal interests.
Id. Accord Valenzuela v. Kraft, Inc., 739 F.2d 434, 435 (9th Cir.1984).
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