On February 18, 2026, the Second Department issued a decision in Sal Savasta, Inc. v. Boar’s Head Provisions Co., Inc., 2026 NY Slip Op. 00924, holding that a plaintiff had adequately alleged a claim for economic duress, explaining:
The fourth cause of action sought to recover damages for economic duress. Economic duress permits a complaining party to void a contract and recover damages when it establishes that it was compelled to agree to the contract terms because of a wrongful threat by the other party which precluded the exercise of its free will. The existence of economic duress or business compulsion is demonstrated by proof that immediate possession of needful goods is threatened or by proof that one party to a contract has threatened to breach the agreement by withholding goods unless the other party agrees to some further demand. Here, the complaint alleged that the defendants threatened to stop selling products to the plaintiffs and to deny approval of the sale of the plaintiffs’ business without justification. These allegations were adequate to allege that the plaintiffs sold their business under unfair conditions and signed releases under economic duress. Accordingly, the Supreme Court should have denied those branches of the defendants’ separate motions which were to dismiss the fourth cause of action insofar as asserted against each of them.
(Internal quotations and citations omitted).