In Ermolieff v. R.K.O. Pictures, Inc. (1942) 19 Cal.2d 543, the California Supreme Court explained that "under proper circumstances" a trial court has discretion to grant or deny declaratory relief depending on whether other remedies -- such as an action for breach of contract -- would "serve as well or better." (Id. at p. 549.) Ermolieff involved a continuing controversy over which party had film distribution rights in the Irish Republic. (Id. at p. 548) As the high court noted, the allegation of a past breach of the distribution agreement did not necessarily bar the trial court's grant of declaratory relief. (Ibid.)