and when Olmsted ultimately, without prompting by the District, submitted his notice of resignation. This period of time provided Olmsted with ample opportunity to reflect on his options. Olmsted claims that Minnesota courts only apply the St. Louis Park factors when a party is claiming duress due to a generic threat. He avers that the factors do not apply in cases involving an unlawful threat. We believe that Minnesota law is to the contrary. See, e.g., Theisen v. Theisen, No. C6-99-2042, 2000 WL 979124, at *2 (Minn. Ct. App. July 18, 2000) (unpublished) (finding that an unlawful threat of physical violence was cured under the factors set forth in St. Louis Park)', Olchefski v. St. Paul Pioneer Press, No. C9-93-417, 1993 WL 302116, at *3 (Minn. Ct. App. Aug. 10, 1993) (unpublished) (<HOLDING>). Moreover, Minnesota law connects duress to
holding that a plaintiff who charged the defendants with conspiring to perpetrate an unlawful purpose could not recover because the defendants committed no unlawful act holding that plaintiff failed to establish pretext where plaintiff was terminated after the employer conducted an investigation into a subordinates allegations of misconduct on the part of the plaintiff and believed the allegations to be true even though plaintiff presented evidence in the lawsuit that the allegations may have been false holding that unlawful threat by defendant to he about plaintiff and deny everything if plaintiff brought a lawsuit were cured under st louis park factors holding that unjust enrichment is brought about by unlawful or improper conduct as defined by law holding that an adequate remedy exists if the plaintiff could assert the issues sought to be declared as a defense in an action brought by the defendant