A lawsuit asking whether James River Insurance Co. can be liable following the death of a Miami nightclub employee was improperly dismissed, the Eleventh Circuit held, disagreeing with how a federal judge weighed relevant factors under the Declaratory Judgment Act.

The federal judge who dismissed James River’s declaratory judgment action in deference to a state court lawsuit failed to consider all relevant issues, the US Court of Appeals for the Eleventh Circuit said Monday. This “lopsided analysis” overlooked the “significant gains in efficiency the declaratory judgment action would generate,” the court said in a ruling by US Circuit Judge Britt …