Duress
Duress: ∆ was coerced by an imminent threat of death or serious bodily harm to commit the offense.
Elements (CL)
- Threat of death or serious bodily harm to ∆ (or sometimes a close other).
- Imminent threat—not future or speculative.
- No reasonable alternative to commission of the offense (e.g., escape).
- ∆ was not at fault in being placed in the coercive situation.
- A person of reasonable firmness would have yielded.
Limits
- NOT a defense to homicide at common law (the law will not condone taking innocent life to save one's own).
- MPC § 2.09 is broader: defense available even to homicide if a person of reasonable firmness would have yielded.
Distinguished from Necessity
- Duress: pressure from another person (human coercer).
- Necessity: pressure from circumstances (storm, fire, accident).
- Duress excuses; necessity justifies.
Cases:
- U.S. v. Contento-Pachon, 723 F.2d 691 (9th Cir. 1984) — duress in drug-courier context.