When someone is harmed because they were deliberately lied to, California law allows recovery under a claim for intentional misrepresentation, often referred to as fraud. CACI No. 1900 explains how juries determine whether a defendant is legally responsible for harm caused by a knowingly false statement.
This instruction applies in a wide range of cases, including consumer fraud, business disputes, employment matters, and product-related misrepresentations.
What Is Intentional Misrepresentation?
Intentional misrepresentation occurs when a defendant knowingly makes a false statement of fact, intends for another person to rely on it, and that reliance causes harm. Unlike negligence, fraud requires knowledge of falsity or reckless disregard for the truth.
CACI No. 1900 sets out the precise elements a plaintiff must prove to establish this claim.
Full Text of CACI No. 1900
CACI No. 1900. Intentional Misrepresentation
[Name of plaintiff] claims that [name of defendant] made a false representation that harmed [him/her/nonbinary pronoun/it]. To establish this claim, [name of plaintiff] must prove all of the following:
- That [name of defendant] represented to [name of plaintiff] that a fact was true;
- That [name of defendant]’s representation was false;
- That [name of defendant] knew that the representation was false when [he/she/nonbinary pronoun] made it, or that [he/she/nonbinary pronoun] made the representation recklessly and without regard for its truth;
- That [name of defendant] intended that [name of plaintiff] rely on the representation;
- That [name of plaintiff] reasonably relied on [name of defendant]’s representation;
- That [name of plaintiff] was harmed; and
- That [name of plaintiff]’s reliance on [name of defendant]’s representation was a substantial factor in causing [his/her/nonbinary pronoun/its] harm.
New September 2003; Revised December 2012, December 2013
How Juries Evaluate Intentional Misrepresentation
Under CACI 1900, jurors focus on several key questions:
- Was a specific statement of fact made, not just an opinion or sales puffery?
- Was the statement false at the time it was made?
- Did the defendant know it was false or act with reckless disregard for the truth?
- Was the statement made with the intent to induce reliance?
- Did the plaintiff reasonably rely on the statement?
- Did that reliance cause actual harm?
All elements must be proven for liability to attach.
Legal Foundation for Fraud Claims
California law has long recognized intentional misrepresentation as a distinct cause of action designed to deter dishonest conduct and protect people who reasonably rely on false statements. The focus is not merely on whether a statement was wrong, but on whether it was knowingly or recklessly false and intended to induce reliance.
Courts use CACI No. 1900 to ensure juries apply a consistent, structured analysis when deciding fraud claims.
Illustrative Example
A company knowingly advertises that a product meets certain safety standards when it does not, intending that consumers rely on that claim. If a buyer relies on the representation and suffers harm as a result, a jury may find intentional misrepresentation under CACI 1900.
Practical Considerations in Fraud Cases
Intentional misrepresentation claims often turn on:
- Emails, advertisements, contracts, or written statements
- Internal documents showing knowledge of falsity
- Evidence of motive and intent
- Proof that the plaintiff’s reliance was reasonable under the circumstances
Because fraud involves intent, these cases frequently rely on circumstantial evidence and credibility determinations.
Speak With a Fraud and Consumer Protection Lawyer
If you were harmed because someone knowingly made false statements to induce your reliance, you may have a claim under CACI No. 1900. WIN Injury & Accident Trial Lawyers can evaluate your case and explain your legal options under California law.
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