Valentine
claimed she was, under a contract with her employer General American
Credit, entitled to job security and peace of mind.Since breach of her employment
contract led to mental distress, she should be able to recover damages.
Valentine
also wanted exemplary damages
(also known as punitive damages) which are generally not given in Contract Law.
Trial
Court dismissed claims of mental distress.
Appellate
Court agreed, stating:
Unless
a contract explicitly includes a provision for "job security"
employment can be terminated at any time by either party.Job security is not an obligation
imposed on an employer by law.
It
is agreed that mental distress could be foreseeable, and she might not be made whole without receiving an award for mental
distress.
Under
Hadley v. Baxendale, damages for
mental distress would be recoverable under literally every breach of
contract!
The
law does not generally compensate for all losses suffered (e.g. legal
fees).In contract actions,
the market price is the general standard.
Mental
distress can be recoverable in contracts with a personal element.These include breach of a promise to marry.However, jobs are generally
economic contracts and do not, as such, contain an element of
personality.An employment contract is not
entered into primarily to secure the protection of personal interests.
