Atchison, Topeka & Santa Fe Railway Co. v. O'Connor, 223 U.S. 280 (1912)

'when, as is common, the State has a more summary remedy, such as distress, and the party indicates by protest that he is yielding to what he cannot prevent, courts sometimes perhaps have been a little too slow to recognize the implied duress under which payment is made' (at 285-86); a party facing forfeiture of its right to do business 'is entitled to assert his supposed right on reasonably equal terms' (at 286).