Valentine v. General American Credit, Inc.

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