Valentine v. General American Credit, Inc. case brief

Valentine v. General American Credit, Inc. case brief summary
 362 N.W.2d 628 (1984)

CASE SYNOPSIS

Plaintiff employee sought review of the decision of the Court of Appeals (Michigan), which affirmed the decision of the trial court dismissing plaintiff's claim to recover mental distress and exemplary damages arising out of an alleged breach of an employment contract by defendant employer.

CASE FACTS
Plaintiff employee brought an action against defendant employer for breach of an employment contract. She alleged mental distress and exemplary damages based on her entitlement to job security and peace of mind associated with the contract. The appellate court affirmed the trial court's dismissal of the mental distress and exemplary damage claims.

DISCUSSION

• The court affirmed the decisions, holding that because plaintiff's employment contract was not entered into primarily to secure the protection of her personal interests, and because pecuniary damages could have been estimated with reasonable certainty, plaintiff could not recover mental distress damages for discharge in breach of her employment contract. 
• The court noted that although such damages were foreseeable, the law did not generally compensate for all losses suffered, the contract was formed to secure an economic interest, and the market place was the standard for assessing damages. 
• The court also denied exemplary damages because plaintiff failed to plead tortious conduct beyond the breach of contract claim.

CONCLUSION
The court affirmed the decisions of the lower courts, which denied plaintiff employee damages for mental distress on her breach of employment contract claim because plaintiff's contract was not entered into primarily to secure protection of her personal interests, and because pecuniary damages were estimable with reasonable certainty. The court affirmed the dismissal of exemplary damages because plaintiff failed to plead tortious conduct.


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