Generally, No Recovery of Mental Anguish on a Tortious Interference with Contract Claim

Generally, mental anguish damages are not recoverable on a claim for tortious interference with a contract. This is because the measure of actual damages for tortious interference with a contract is the same as the measure of damages for breach of the interfered-with contract, and mental anguish damages generally are not available for breach of a contract. Mental anguish damages are available in "a very limited number of contracts dealing with intensely emotional noncommercial subjects such as preparing a corpse for burial or delivering news of a family emergency." See City of Tyler v. Likes, 962 S.W.2d 489, 496 (Tex. 1997)