Section 4.6 Emotional Distress

• Library: Contracts 2016 Supp

4. (§4.6) Emotional Distress

Damages for emotional or mental distress, disappointment, and similar categories of claims are not ordinarily awarded in breach of contract actions. Standley v. Chilhowee R-IV Sch. Dist., 5 F.3d 319 (8^th Cir. 1993); Wells v. Holiday Inns, Inc.,522 F. Supp. 1023 (W.D. Mo. 1981). These types of damages typically are disallowed because they are uncertain and not reasonably predictable in connection with contract matters. Wells, 522 F. Supp. at 1028. In ordinary breach of contract cases, the courts are inclined to view a breach of a contract purely in terms of the economic consequences, which the parties can fairly appraise in making a determination to perform or break a contract obligation. Id. In recent cases, no Missouri courts have...