Not necessarily. In most circumstances there's no duress since a patient can visit a different physician. The case of someone who is in severe pain, has already waited 3 days, and has every reason to think that he might need to wait another 3 days if he opts to see a different physician is an exceptional one.

(And even in the absence of a contract, there's a quasi-contract, so a finding of duress wouldn't obviate the requirement to pay for services rendered.)

It also depends on the definition of duress. Is it how much pain the person is in (which is a psychological perception), or how life-threatening their condition is.

This guy had a severe tooth ache and I can't really gather much more FTA for what he actually had. However, there's cracked teeth and abscesses that dentists see frequently that are expected to be much more painful.

I personally just don't feel dental pain, so what are the grounds for duress with me. I found out I'd had 5 cavities, potentially for over a year (it had been around 2 years since my last dental visit because of moving country and having no benefit plan) and I had no clue.