dissenting.
Because I believe the Reeds’ homeowners’ policy unambiguously excludes coverage for *702liability arising from the death of Michael Ford III, I dissent.
Before attempting to interpret and apply the Reeds’ policy to the facts of this case, it is important to consider the nature of Ms. Reed’s child care enterprise at the time of Michael Ford’s death. From 1984 to just after Michael’s death, Ms. Reed operated one of over 14,000 “registered family homes” in the state, which are authorized by the Texas Department of Human Resources (TDHR) to provide day care services for as many as 12 children at a time.1 Ms. Reed charged parents $37.50 per child, per 5-day week for her services. The scale of Ms. Reed’s enterprise apparently required, and the revenue from it allowed, her to hire two additional employees. Her range of clients extended beyond mere family and close friends, as she advertised her services, while the Fords, for example, relied on third-party recommendations.
As a registered family home, Ms. Reed’s enterprise was required to comply with a variety of TDHR regulations designed to ensure the safety of children under her supervision. One requirement was that “[i]f there is a swimming pool, wading pool, pond, creek, or other body of water on or near the premises of the home, children must be protected from unsupervised access to the water.” Texas Department of Human ResouRces, Stock Code 20320-0000, Minimum Standards: Registered Family Homes Appendix I, at 10 (April 1982); see also TexAd-min.Code § 81.106. When originally constructed in 1982 or 1983, the Reeds’ swimming pool was not separated by a fence or other barrier from the rest of their back yard. In deposition testimony, Ms. Reed confirmed that the hurricane fence now separating the pool from the children’s play area was later added to help meet the TDHR safety requirements. Michael Ford gained access to the pool by crawling under this fence through a hole allegedly dug by the Reeds’ family dog.
When the Reeds bought their house in 1982 or 1983, they purchased a Texas standard homeowners policy, mandated by State Board of Insurance regulations and held by over four million other Texas homeowners, which they renewed annually. This policy contains strict limits on coverage of risks arising from business activities, defining “business” as “trade, profession, or occupation.” One of the Reeds’ declarations in the policy disclaimed that any “business pursuits” were conducted in their home, and a space for exceptions to that declaration was left blank. They continued to make this disclaimer with each successive renewal, even after Ms. Reed initiated her child care enterprise. The policy contained an exclusion to personal liability coverage for “business pursuits,” and an exception to that exclusion for “activities therein which are ordinarily incident to non-business pursuits.” While other types of coverage were available for business activities, the Reeds did not purchase any of these; rather, with each successive renewal, they continued to rely solely on their basic homeowners’ policy to ensure them against risks arising from Ms. Reed’s child care enterprise.
The Reeds do not dispute that the child care enterprise constituted a “business pursuit” under the meaning of the policy; instead, they argue that because the “incident to non-business pursuits” exception is ambiguous, we should apply the contra-drafter rule to find coverage. When construing a contract, the court’s primary concern must be to give effect to the written expression of the parties’ intent. E.g., Ideal Lease Serv., Inc. v. Amoco Prod. Co., 662 S.W.2d 951, 953 (Tex.1983). The interpretation of a contract, and the issue of whether a contract has more than one reasonable interpretation, are questions of law which we must resolve by read-*703mg the contract as a whole. Reilly v. Rangers Mgt., Inc., 727 S.W.2d 527, 529 (Tex.1987); Coker v. Coker, 650 S.W.2d 891, 393 (Tex.1983). Applying these rules to the case at hand leads me to conclude that there is only one reasonable interpretation of the contested policy provisions: the Reeds are not covered.
I agree that where a provision of an insurance policy, like that in any other contract, is ambiguous, or susceptible to more than one reasonable interpretation, such uncertainty should be resolved against the drafter. National Union Fire Ins. Co. v. Hudson Energy Co., 811 S.W.2d 552, 555 (Tex.1991); Barnett v. Aetna Life Ins. Co., 723 S.W.2d 663, 665 (Tex.1987). But not every difference in the interpretation of a contract amounts to an ambiguity. And certainly the fact that other jurisdictions are in disagreement cannot, by itself, justify a holding that language is ambiguous. See Rodriguez v. Safeco Ins. Co., 821 P.2d 849, 853 (Colo.App.1991); Allstate Ins. Co. v. Kelsey, 67 Or.App. 349, 678 P.2d 748, 752 (1984); Floyd v. Northern Neck Ins. Co., 245 Va. 153, 427 S.E.2d 193, 196-97 (1993); McCloskey v. Republic Ins. Co., 80 Md.App. 19, 559 A.2d 385, 387 (1989).
Admittedly, a few courts in other states have, in similar fashion and in similar contexts, deemed “incident to non-business activities” exclusions ambiguous or have otherwise applied the contra-drafter rule to find coverage. See State Farm, Fire & Cas. Co. v. Moore, 103 Ill.App.3d 250, 58 Ill.Dec. 609, 615, 430 N.E.2d 641, 647 (1981); Foster v. Allstate Ins. Co., 637 S.W.2d 655, 657 (Ky.App.1981); Robinson v. Utica Mut. Ins. Co., 585 S.W.2d 593, 598 (Tenn.1979); see also Nationwide Mut. Fire Ins. Co. v. Collins, 136 Ga.App. 671, 222 S.E.2d 828, 832-32 (1975). Many more states, however, including all who have considered such provisions in the last decade, have held them not to be ambiguous. See Stanley v. American Fire & Cas. Co., 361 So.2d 1030, 1033 (Ala.1978); Rodriguez, 821 P.2d at 853; Western Fire Ins. Co. v. Goodall, 658 S.W.2d 32, 34 (Mo.App.1983) (citing Dieckman v. Moran, 414 S.W.2d 320 (Mo.1967)); Haley v. Allstate Ins. Co., 129 N.H. 512, 529 A.2d 394, 396 (1987); Kelsey, 678 P.2d at 752; Floyd, 427 S.E.2d at 196-97; Rocky Mtn. Cas. Co. v. St. Martin, 60 Wash.App. 5, 802 P.2d 144, 146 n. 3 (1990); see also Republic Ins. Co. v. Piper, 517 F.Supp. 1103, 1106 (D.Colo.1981); McCloskey, 559 A.2d at 387 (construing “business pursuits” exclusion).
The act of supervision is the very essence of child care. That is what Ms. Reed was paid to do, and it is her failure to perform this duty that proximately caused Michael Ford’s death. I thus reject the view that in determining whether the “incident to non-business” exception applies, we should focus on some more specific act — for example, the failure to maintain the fence — that might be said to have caused the injury. See Gulf Ins. Co. v. Tilley, 280 F.Supp. 60, 65 (N.D.Ind.1967), aff'd per curiam, 393 F.2d 119 (7th Cir.1968); Rodriguez, 821 P.2d at 852; Floyd, 427 S.E.2d at 197.2 See also Developments in Maryland Law: Insurance Coverage of Injuries that Occur at Home DayCare, 49 Md.L.Rev. 509, 824 (1990).
While a handful of early cases suggested that the act of supervising a child might be “incident to nonbusiness pursuits,” see Crane v. State Farm Fire & Casualty Co., 5 Cal.3d 112, 95 Cal.Rptr. 513, 485 P.2d 1129, 1132 (Cal.1971); Bankers Standard Ins. Co. v. Olwell, 309 N.W.2d 799, 801-02 (Minn.1981); Goodall, 658 S.W.2d at 34-35, these cases stand for the outmoded rationale that child supervision, even if for compensation, is somehow inherently “incident to non-business activities.” This fails to comport with the modern realities of working parents, necessitating the proliferation of professional day care providers like Ms. Reed. Perhaps reflecting this, more recent decisions have *704uniformly repudiated the view that child care is always “nonbusiness.” See Stanley, 361 So.2d at 1033; Farmers’ Ins. Co. of Arizona v. Wiechnick, 166 Ariz. 266, 801 P.2d 501, 504 (Ct.App.1990); Landis v. Allstate Ins. Co., 546 So.2d 1051, 1053 (Fla.1989); Moncivais v. Farm Bureau Mut. Ins. Co., 430 N.W.2d 438, 442; McCloskey, 559 A.2d at 390; Maryland Casualty Co. v. Hayes, 827 S.W.2d 275, 278 (Mo.App.1992);3 Haley v. Allstate Ins. Co., 129 N.H. 512, 529 A.2d 394, 396 (1987); Kelsey, 678 P.2d at 750-52; Rocky Mtn. Cos. Co., 802 P.2d at 147; see also Piper, 517 F.Supp. at 1106; United States Fidelity & Guar. Co. v. Heltsley, 733 F.Supp. 1418, 1422-23 (D.Kan.1990).
I reject the notion that the supervision of children in full-time, for-profit, state-regulated residential child care enterprises can reasonably be deemed “incident to non-business pursuits.”4 The Reeds’ Texas standard homeowners’ policy was not intended to cover risks arising out of that or any other business pursuit.
One necessarily sympathizes with the plight of the Fords, who understandably desire the adequate and sure source of compensation for their son’s tragic death that the Reeds’ homeowners’ policy might provide. But it is not the job of this Court to ensure such coverage where the policy at issue unambiguously excludes it. And, under this language, it is not the responsibility of the four million other Texans who have homeowners’ policies to subsidize the business risks of the homeowner who initiates an at-home enterprise subject to certain risks without purchasing appropriate coverage.
I would reverse the judgment of the court of appeals and render summary judgment in favor of State Farm.
HECHT, J., joins in this dissent.
. Chapter 42 of the Human Resources Code, "Regulation of Child-Care Facilities,” defines a "family home” as follows:
[A] home that regularly provides care in the caretaker’s own residence for not more than six children under 14 years of age, excluding the caretaker's own children, and that provides care after school hours for not more than six additional elementary school children, but the total number of children, including the caretaker's own, does not exceed 12 at any given time.
Tex.Hum.Res.Code. § 42.002(9). The Reeds registered their family home with the TDHR as required under Section 42.052 of the Code. Id., § 42.052(c).
. The Court points out that the trial court’s judgment expressly referenced the Reeds' failure "to maintain the premises” as the basis for its holding. 873 S.W.2d at 700 n. 2, n. 6. As this is a question of law rather than fact, however, the trial court’s articulated reason is not entitled to deference on appeal.
Even under this approach, however, I disagree that the act of maintaining the fence could reasonably be viewed as “incident to nonbusiness activities.” As I have explained, the Reeds were required, under the applicable state regulatory scheme, to build and maintain the fence to ensure that children did not obtain unsupervised access to the water. Cf. Economy Fire & Cas. Co. v. Bassett, 170 Ill.App.3d 765, 121 Ill.Dec. 481, 484, 525 N.E.2d 539, 542 (1988).
. But see Goodall, 658 S.W.2d at 34.
. In so doing, however, I do not categorically suggest that Texas standard homeowners’ policies would exclude coverage of liability arising from any for-profit child care undertaken in the home. Certainly such activities as part-time babysitting by teenagers for a neighbor’s child, even while compensated, would not fall into the same category as Ms. Reed’s full-time business. See United. Serv. Auto. Ass’n v. Pennington, 810 S.W.2d 777, 780-82 (Tex.App.—San Antonio 1991, writ denied).