Neibuhr v. Gage - 99 Minn. 149, 108 N.W. 884 (1906)

Rule:

A party who has been injured by duress is entitled to the same remedies which are available in cases of deceit. In some cases, there is no doubt but that exact justice between the parties can more generally be effected in equitable proceedings than in actions at law for damages. It is just and reasonable that one who seeks to repudiate a contract should do everything that is reasonably within his power to reinstate the parties in their original conditions.

Facts:

Plaintiff stockholder held shares of stock in defendant's company. Defendant detained the stockholder in his office and accused him of unlawfully appropriating money that belonged to defendant. Furthermore, defendant refused to release the stockholder until the stockholder conveyed to defendant his shares of stock, which the stockholder did. The stockholder then filed an action that alleged he was deprived of his property through defendant's duress. The jury found in favor of the stockholder, but the trial court granted defendant's motion for a new trial. Plaintiff challenged the decision. 

Issue:

Under the circumstances, did the trial court properly grant defendant's motion for a new trial? 

Answer:

No.

Conclusion:

On review, the court found that defendant was not entitled to a new trial. The court reasoned that it was immaterial whether the contract was void or voidable. Additionally, the evidence showed that the stockholder conveyed his stocks under duress, and that he was entitled to the same remedies as one injured by fraud. Therefore, the order granting a new trial was reversed with directions to the trial court to enter a judgment in favor of the stockholder.