In general, as shown in Valentine v. General American Credit Inc. (362 N.W.2d 628 (Mich. 1984)), punitive damages are never awarded for breach of contract. But that isn’t 100% true. For example, in the case of Stewart v. Rudner (349 Mich 459; 84 N.W.2d 816 (1957)), a doctor explicitly promised to deliver a child via caesarean section. He did not perform the operation, and the baby was stillborn. In this case, the losses were wholly psychological (how much is a baby worth?), and so the Court agreed that mental distress is recoverable from this breach of contract. This difference between this case and Valentine is that Valentine was an economic contract, while in this case the contract contained an element of personality.