California Codes
Cal. Civil Code § 1570 (2026)
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✓ leginfo export of Sept. 26, 2026 (applied Oct. 1, 2026)
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Menace consists in a threat:
1.Of such duress as is specified in Subdivisions 1 and 3 of the last section;
2.Of unlawful and violent injury to the person or property of any such person as is specified in the last section; or,
3.Of injury to the character of any such person.
Notes of Decisions
Cited in 5
cases (1 in the last 5 years), 1942–2023 · 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). “" Civil Code section 1570 provides: " Menace, what.”
Odorizzi v. Bloomfield Sch. Dist., 246 Cal. App. 2d 123 (Cal. Ct. App. 1966). “(Civ. Code, § 1570; Rest., Contracts, §§492, 493.”
People v. Moore, 196 Cal. App. 2d 91 (Cal. Ct. App. 1961). “) All of the elements of this offense are included in the statement of facts heretofore outlined; the threats to arrest Miss Wilks and take her children from her constitute a menace (Civ. Code, § 1570); proof of the use of force was not necessary to establish the unlawful taking…”
Miller v. Walden, 127 P.2d 952 (Cal. Ct. App. 1942). “Walden on account of the transaction, and therefore no duress (Civ. Code, § 1570; Morrill v. Nightingale, 93 Cal.”
Tran v. Nguyen, 97 Cal. App. 5th 523 (Cal. Ct. App. 2023). “” Civil Code section 1569 defines “[d]uress” as the confinement of a party or family member; Civil Code section 1570 defines “[m]enace” as the threat of duress, of “unlawful and violent injury to [a] person or property,” or of “injury to the character of 7 [a] person.”
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