[1999] Frazer v. Montana State Fund [07/20/05] 2005 MTWCC 41 To reopen a settlement on grounds of duress, the claimant must prove “(1) unlawful confinement of the person of the party, of the husband or wife of such party, or of an ancestor, descendant, or adopted child of such party, husband, or wife; (2) unlawful detention of the property of any such person; or (3) confinement of such person, lawful in form but fraudulently obtained or fraudulently made unjustly harassing or oppressive.”