White v. Benkowski
Citation: Supreme Court of Wisconsin, 37 Wis. 2d 285 (1967)
Facts
The Whites and Benkowskis were neighbors who entered a contract allowing the Whites to use the Benkowskis’ private water supply for ten years in exchange for payment and assistance with water system maintenance. The Benkowskis periodically shut off the water supply, allegedly out of spite, causing inconvenience to the Whites. The Whites sued for breach of contract and sought both compensatory and punitive damages.
Issue
Whether a plaintiff may recover punitive damages or damages for mental distress in a breach of contract action.
Holding
The court held that punitive damages are not recoverable in a breach of contract action and reversed the punitive damages award. It affirmed that nominal compensatory damages were appropriate but disallowed the mental distress component of the compensatory award.
Rule
Punitive damages are not available for breach of contract. Damages for mental distress are generally not recoverable in contract actions; contract damages are limited to economic loss.
Significance
A foundational case for teaching the general rule that contract damages are compensatory only and do not include punitive damages or emotional distress, distinguishing contract remedies from tort remedies. It frames the principle that the goal of contract damages is to put the non-breaching party in the position they would have been in had the contract been performed, not to punish the breaching party.