ContractsProf Blog

Editor: Myanna Dellinger
University of South Dakota School of Law

Monday, October 24, 2005

Court Denies Recovery for Mental Anguish on Breach of Contract Claim

A hotel manager refused to rent a room to a blind man (plaintiff) because he was accompanied by a guide dog. Plaintiff sued the hotel and its manager, asserting federal and state discrimination claims and various tort claims. Plaintiff also sued on a breach of contract theory. The hotel moved for summary judgment on the breach of contract claim, arguing that mental and emotional damages alone are insufficient to maintain a breach of contract action. The District Court for the Middle District of Alabama granted the motion for summary judgment and dismissed the breach of contract claim.

The court noted:

The general rule is that plaintiffs may not recover for mental anguish on breach of contract claims. However, an exception to this rule exists "where the contractual duty or obligation is so coupled with matters of mental concern or solicitude, or with the feelings of the party to whom the duty is owed, that a breach of that duty will necessarily or reasonably result in mental anguish or suffering." (citations omitted)

The court held that contracts for the rental of hotel rooms did not fall within this exception, and observed that "the majority of cases falling within this exception regard breaches of contract that render homes uninhabitable." However, the court distinguished a hotel room from a home:

While hotel rooms may take on the temporary role of one's "castle," as a home would, hotel rooms are drastically dissimilar from homes in terms of the amount of money invested, the amount of care taken in upkeep, and the amount of thought and emotional concern invested.

Hardesty v. CPRM Corp. (M.D. Ala. Jun. 1, 2005)

[Meredith R. Miller]

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