Fifty-seven years ago, the noted contracts scholar John P. Dawson stated: [T]he modern American law of duress reflects the convergence of several lines of growth, originally moving from sources quite distinct. The symptom of this convergence has been an increasing interplay and transfer of ideas. Its result has certainly not been a coherent body of doctrine, unified around some central proposition; on the contrary, the conflict and confusion in results of decided cases seems greater that ever before. John P. Dawson, Economic Duress—An Essay in Perspective, 45 Mich. L. Rev. 253, 288 (1947). Dawson's conclusion about "conflict and confusion" of results in actual cases remains true today. Even after the passage of half a century since Dawson's observations, the duress doctrine remains largely unusable, though courts frequently do attempt to use it. The time has come for a coherent and usable duress doctrine based on clear principles. To once more gain sight of the ultimate goal of justice, courts must abandon the practice of analyzing the presence or absence of free will to identify a situation of constrained choice. The “free will” test must be scrapped in favor of the more instrumental "no reasonable alternative" test. This test more appropriately determines whether a situation is one of substantially constrained choice. Use of such a test also will minimize the consideration of the contractor's decision-making capacity and will refocus attention on the constrained nature of the choice before even the most able contractor. In addition, courts must break free of the language of earlier courts and recognize that duress can be based on threats of crimes or torts, threats that are criminal or tortious, threats of criminal prosecution, threats of bad faith use of civil prosecution, and bad faith within an existing contractual relationship. Finally, any attempt to use the duress doctrine as a direct regulator of the substantive fairness of deals should be abandoned. Courts have rejected such a role in general and have rejected such a role for the duress doctrine even in the face of urging by commentators and the Restatement itself.