What is the test for establishing a sixth cause of action as an independent claim for declaratory and injunctive relief?
MultiRegion, United States of America
The following excerpt is from Chittenden v. United States, No. 2:16-cv-2401 MCE CKD PS (E.D. Cal. 2016):
Insofar as plaintiffs premise their sixth cause of action as independent claims for declaratory and injunctive relief, it is not cognizable as a matter of law. Santos v. Countrywide Home Loans, 2009 WL 3756337, at *5 (E.D. Cal. Nov. 6, 2009) ("Declaratory and injunctive relief are not independent claims, rather they are forms of relief.").
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