Valentine v. General
American Credit, Inc.
Supreme Court of
420
Facts: Valentine alleged that her employment contract was
broken. She sued for mental distress due
to loss of job security. Her mental
distress claims were dismissed at trial, and the decision was upheld on
appeal. She appealed to the Supreme
Court of Michigan.
Issue: Can an employee who loses their job sue for mental
distress?
Rule: Mental distress damages for breach of contract are
not recoverable except when the contract has a personal element or when the
damage suffered due to breach cannot be compensated within the terms of the
contract.
Analysis: The court argues that breaches of contract always
cause annoyance, but the law does not allow a plaintiff to recover for such
annoyance. The court says there are many
cases where the law does not allow a full recovery. The rule of foreseeability from Hadley
is not properly applied to this case.
Conclusion: The judgment of the lower courts was affirmed, and
the plaintiff received no mental distress damages or exemplary damages.
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Damages