The following excerpt is from United States v. Lopez, 913 F.3d 807 (9th Cir. 2019):
superseded on other grounds in Martinez v. Martinez , 369 F.3d 1076, 1089 (9th Cir. 2004), we considered the duress defense in the context of women convicted of drug offenses, who asserted that the drug kingpin for whom they worked abused and "psychologically threatened" them. Id. at 90102. We phrased the issue in the following manner: "The question, relevant to the defense of duress in the cases before us, is whether a special vulnerability to feara vulnerability not produced by those persons causing the defendants criminal actionmay be taken into account." Id . at 898. We resolved the issue by answering the question in the negative: "As a defense to a charge of criminal conduct, such subjective vulnerability has not been admitted ." Id. (emphasis added).
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