contract-law labor-law workplace assault arbitration
Looking for any case that connects an assault and the signing of arbitration agreements, possible duress
<p>Heading off the obvious response; I have already tried multiple search engines. There is so much "noise" from unrelated cases that I can't find what I'm looking for with a simple web search. I'm looking for a case from a U.S. federal appeals court. The case was appealed because the lower court had applied regular contract law and the business was trying to ignore duress in light of a then-new S.C.o.t.U.S. ruling that had to do with how courts would weigh concerns related to enforceability of contracts when those contracts had to do with arbitration. The federal appeals court (I don't remember which circuit) chose to say an assault did create duress, even for an arbitration contract. This case was not later picked up by the U.S. Supreme Court for review.</p>

<p>Here's a way to word this: "Does committing an assault against someone earlier the same day mean they're under duress for contract purposes?"</p>

<p>I've been reading legal blogs and listening to law-related podcasts for a while and I remember a case I now want to go back and look up. I am having trouble finding the actual citation and any documents about the ruling. The case related to an invalidated arbitration agreement. The person suing their employer had been the victim of a physical assault. The employer forced the employee to sign an arbitration agreement right after the assault, and the court ruled that was an invalid contract because the assault allegation showed they were under duress. I'm aware that the current S.C.o.t.U.S. view is that arbitration has weird ideas attached. Ideally I would like the actual case citation that states an assault invalidates arbitration, presumably because of duress expectations in contract law.</p>

<blockquote>
  <p>Does committing an assault against someone earlier the same day mean
  they're under duress for contract purposes? I am having trouble
  finding the actual citation and any documents about the ruling.</p>
</blockquote>

<p>The results of <a href="http://www.leagle.com/leaglesearch?all=contract+arbitration+duress+assault+labor+employer" rel="nofollow noreferrer">this query</a> might help. The lack of detail in your question makes it impossible to further narrow it down from the 52 opinions currently listed. In several those opinions, you will find citations (for example, <a href="https://www.leagle.com/decision/infdco20190501e84" rel="nofollow noreferrer">here</a>) in the sense that </p>

<blockquote>
  <p>"Like other contracts . . . [arbitration agreements] may be
  invalidated by `generally applicable contract defenses, such as fraud,
  duress, or unconscionability.'" Rent-A-Center, W., Inc. v. Jackson,
  561 U.S. at 68 (quoting Doctor's Assocs., Inc. v. Casarotto, 517 U.S.
  681, 687 (1996))</p>
</blockquote>

<p>Assault is very likely to qualify as duress and/or unconscionability that invalidates an agreement.</p>
