In general, mental distress can be recoverable in contracts with a personal element (See Valentine v. General American Credit Inc. (362 N.W.2d 628 (Mich. 1984))). The decision in Hancock v. Northcutt (808 P.2d 251 (Alaska 1991)) held that contracts relating to one’s dwelling lack a personal element. The Court found that to permit emotional distress damages on a contract claim for negligent construction of a personal residence would make the financial risks of construction agreements difficult to predict. Only in contracts where ‘emotional tranquility’ is the contract’s essence can emotional distress be recoverable. So basically, if someone negligently ruins your house, you can sue them for the damage to the house, but most of the time you cannot get any extra money because you are sad that you lost your house.