California Codes

Cal. Civil Code § 1569 (2026)

✓ current as of May 2026
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Duress consists in any of the following:

(a)Unlawful confinement of the person of the party, or of the spouse of such party, or of an ancestor, descendant, or adopted child of such party or spouse.

(b)Unlawful detention of the property of any such person.

(c)Confinement of such person, lawful in form, but fraudulently obtained, or fraudulently made unjustly harassing or oppressive.

Notes of Decisions
Cited in 18 cases (7 in the last 5 years), 1953–2025 · leading case: People v. Cicero, 157 Cal. App. 3d 465 (Cal. Ct. App. 1984).
People v. Cicero, 157 Cal. App. 3d 465 (Cal. Ct. App. 1984). · cites it 2× “" Civil Code section 1569 provides: " Duress, what.”
Rich & Whillock, Inc. v. Ashton Dev., Inc., 157 Cal. App. 3d 1154 (Cal. Ct. App. 1984). · cites it 2× “(Civ. Code, § 1569, subd. 2; 2 Burke v. Gould, supra, 105 Cal.”
Tarpy v. Cnty. of San Diego, 2003 Cal. Daily Op. Serv. 5970 (Cal. Ct. App. 2003). “(Civ. Code, § 1569.) Statutory duress requires confinement or detention that is unlawful, to wit, resulting from a tortious or criminal act.”
In Re the Marriage of Baltins, 212 Cal. App. 3d 66 (Cal. Ct. App. 1989). “) 7 Civil Code section 1569, unchanged since its enactment in 1872, provides: “Duress consists in: [][] 1.”
Gonzalez v. Gonzalez, 57 Cal. App. 3d 736 (Cal. Ct. App. 1976). “Civil Code section 1569 provides in pertinent part as follows: “Duress consists in: “1.”
Odorizzi v. Bloomfield Sch. Dist., 246 Cal. App. 2d 123 (Cal. Ct. App. 1966). “(Civ. Code, § 1569.) Duress is often used interchangeably with menace (Leeper v.”
Keithley v. Civil Serv. Bd., 11 Cal. App. 3d 443 (Cal. Ct. App. 1970). “Civil Code section 1569, in relevant part, defines duress as either the “1.”
Haden v. Haden, 262 P.2d 73 (Cal. Ct. App. 1953). “(Civ. Code, § 1569.) Respondent did neither.”
Fio Rito v. Fio Rito, 194 Cal. App. 2d 311 (Cal. Ct. App. 1961). “46-48) ; the duress, she claims, was “the unlawful detention of the property” by plaintiff (Civ. Code, § 1569, subd. 2) when he clouded its title by the divorce action.”
Haddad v. Shell Oil Co., 423 F. Supp. 1384 (C.D. Cal. 1976). “Haddad’s allegations concerning the circumstances under which he executed the termination agreements with respect to the four automobile service stations referred to in paragraph 1 do not constitute duress as that term is used in California Civil Code Section 1569 or economic or…”
Estrada v. Real Time Resolutions Inc. (N.D. Cal. 2025). · cites it 3× “…in violation of the Fair Debt Collection Practices 22 Act, 15 U.S.C. § 1692e; 10) financial duress under California Civil Code §§ 1542, 1569 and 1692; 23 and 11) resetting statute of limitations for claims brought under California Civil Code §§ 1569 and 24 1692.…”
Estrada v. Real Time Resolutions Inc. (N.D. Cal. 2025). · cites it 2× “…in violation of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692e; 10) 11 financial duress under California Civil Code §§ 1542, 1569 and 1692; and 11) resetting statute of 12 limitations for claims brought under California Civil Code §§ 1569 and 1692. ECF…”
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