COFFIN, Senior Circuit Judge.
As part of a severance agreement, plaintiffs signed releases waiving all claims against their former employer. Three and one half years later, contending that the releases had been coerced, they brought this ERISA suit. The district court dismissed, applying the common law rule that a party may not avoid a contract based on duress without first returning the consideration received. We express no view on whether ERISA plaintiffs must satisfy...
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