Valentine v. General American Credit, Inc.

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Facts: Plaintiff sued for mental distress caused by dismissal from Defendant employer.

Issue: If that mental distress is foreseeable when you lose a job, should it be considered part of consequential damages?

Holding: Held for Defendant.

Reasons:

  • The main purpose of the contract was economic, not mental health.
    • Policy: Every business risk has mental element
    • One always has emotional distress when he loses a job
  • The purpose of contract law is to compensate, not to punish. Law will grant emotional damages for breach only when the contract has a personal element, such as:
    • delivery of a baby or
    • marriage K
  • Exceptions:
    • insurance refuses claim in bad faith (special relationship of insurance and client) or
    • a tort is committed