Declaratory judgment actions brought under Pennsylvania’s Declaratory Judgments Act, 42 Pa. C.S. Sections 7531-41, present knotty questions of appealability. See, Affordable Outdoor v. Tri-Outdoor, 210 A.3d 270, 275 (Pa. Super. 2019) (referencing “complicated jurisprudence surrounding declaratory judgments”). If the order resolves the entire action, then the answer is easy. The order, once it has been reduced to judgment (under Pa. R.A.P. 905(a)(5), appeals are from judgments, not orders—a common mistake), is final and appealable as of right. But even if the result in a declaratory judgment action does not decide everything, it may nonetheless be an appealable interlocutory appeal under Pa. R.A.P. 311(a)(8), which provides that “an appeal may be taken as of right” from “an order that is made final or appealable by statute or general rule, even though the order does not dispose of all claims and of all parties.”

The Declaratory Judgment Act is such a statute. It provides that courts of record have the power “to declare rights, status and other legal relations” and that “such declarations shall have the force and effect of a final judgment or decree.” The Pennsylvania Supreme Court’s most recent encounter with Section 7532 was Pennsylvania Manufacturers’ Association Insurance v. Johnson Matthey, 188 A.3d 396 (Pa. 2018) (per curiam), which held that an order denying an insurer’s declaratory judgment in toto was not appealable where the insured had filed a counterclaim, also for declaratory relief, that remained undecided.