Hancock v. Northcutt 808 P.2d 251 (Alaska 1991) agreed that contracts relating to one's dwelling
also lack a personal element, similar to Valentine v. General
American Credit Inc..To permit emotional distress damages on
a contract claim for negligent construction of a personal residence would make
the financial risks of construction agreements difficult to predict.Only in contracts where 'emotional
tranquility' is the contract's essence can emotional distress be recoverable.