Western Bagel v. Superior Court (Calderon)

 The Federal Arbitration Act preempted the use of the constructive canon of contra proferentem to infer from a purported ambiguous agreement that the parties consented to nonbinding arbitration; the doctrine cannot be a substitute for the requisite affirmative contractual basis for concluding the parties had agreed to forgo the central benefits of arbitration itself by submitting their disputes to nonbinding arbitration.

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