In Sesay v. Attorney General, the Third Circuit, faced with the tragic plight of a citizen of Sierra Leone forced to perform menial tasks for a rebel group who repeatedly beat him, affirmed the Board of Immigration Appeals' determination that Sesay's actions qualified as material support to a terrorist group. Moreover, the Court declined to read a duress exception into the statute, and noted that only the Department of Homeland Security has the authority to waive the material support bar based on duress.
The full text of Sesay v. Attorney General can be found here: http://www2.ca3.uscourts.gov/opinarch/142996p.pdf