California Codes
Cal. Civil Code § 1654 (2026)
✓ current as of May 2026
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In cases of uncertainty not removed by the preceding rules, the language of a contract should be interpreted most strongly against the party who caused the uncertainty to exist.
Notes of Decisions
Cited in 304
cases (45 in the last 5 years), 1946–2026 · leading case: Lamps Plus, Inc. v. Varela, 139 S. Ct. 1407 (2019).
Lamps Plus, Inc. v. Varela, 139 S. Ct. 1407 (2019). “3d, at 514 ; see Cal. Civ. Code Ann. §1654 (West 2011); see also Brief for Contract Law Scholars as Amici Curiae 10–12, and n.”
Badie v. Bank of Am., 98 Cal. Daily Op. Serv. 8189 (Cal. Ct. App. 1998). “When ambiguities in a standardized contract, like the account agreement involved here, cannot be dispelled by application of the other, rules of contract interpretation, they are resolved against the drafter.”
Sandquist v. Lebo Auto., Inc., 376 P.3d 506 (Cal. 2016). “He is also more likely than the other party to have reason to know of uncertainties of meaning.”
Victoria v. Superior Court, 710 P.2d 833 (Cal. 1985). “Enacted as a part of the Medical Injury Compensation Recovery Act (MICRA), section 1295 provides that any contract for medical services which contains an arbitration provision must include certain specified language alerting the patient to the scope and nature of the arbitration.”
Signal Companies, Inc. v. Harbor Ins. Co., 612 P.2d 889 (Cal. 1980). “(Civ. Code, § 1654; Masonite Corp. v. Pacific Gas & Electric Co.”
Teamsters, Local 396 v. Nasa Servs., Inc., 957 F.3d 1038 (9th Cir. 2020). “Cal. Civ. Code § 1654 . Foremost among those preceding principles, for our purposes, is the mandate that contracts be construed as a whole.”
Kashmiri v. Regents of the Univ. of California, 67 Cal. Rptr. 3d 635 (Cal. Ct. App. 2007). “” The University had complete control over what language to use in its catalogues and on its Web sites. It is well established that “[i]n cases of uncertainty not removed by [other] rules, the language of a contract should be interpreted most strongly against the party who…”
DVD Copy Control Assn., Inc. v. Kaleidescape, Inc., 176 Cal. App. 4th 697 (Cal. Ct. App. 2009). “One reason the trial court might have been concerned with whether the license was unfairly adhesive would have been to decide how forcefully to apply the doctrine of contra proferentem the rule that unresolved ambiguities in a contract are to be interpreted against the drafter.”
Asmus v. Pac. Bell, 999 P.2d 71 (Cal. 2000). “) To the extent it is unclear how the occurrence of a change materially affecting Pacific Bell's business plan achievement can be ascertained or measured, we must conclude the condition reasonably may be ascertained by reference to its purpose.”
Founding Members of Newport Beach Country Club v. Newport Beach Country Club, Inc., 2003 Cal. Daily Op. Serv. 5101 (Cal. Ct. App. 2003). “Founding Members argues that any ambiguities in the governing regulations must be resolved against NBCC because it drafted them (Civ. Code, § 1654) and that if “the terms of a promise are in any respect ambiguous or uncertain, it must be interpreted in the sense in which the…”
Bareno v. Employers Life Ins., 500 P.2d 889 (Cal. 1972). “The basic question that lies before us turns on whether the certificate's 31-day extension provisions apply to the disability benefits in the policy or merely to the life insurance benefits. We conclude that the certificate and the separate notice of terminated employee's…”
Penthouse Int'l, Ltd., a New York Corp. v. Priscilla Barnes, 792 F.2d 943 (9th Cir. 1986). “To the degree that the Penthouse printed release form might allow Penthouse to use a model’s real name, the handwritten addition of “AKA” controls the printed release form.”
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