Torrance County Mental Health Program, Inc. v. New Mexico Health & Environment Department

OPINION

MONTGOMERY, Justice.

In this case we answer the question whether punitive damages may be recovered from a governmental entity in an action for breach of contract. We also consider two other damage issues arising under the particular facts in the case and the evidence at trial: whether damages for the plaintiff corporation’s “loss in value” caused by the defendant’s breach of contract were properly awarded, and whether the plaintiff could recover damages for its employees’ efforts in winding up the contract after defendant terminated it.

The first issue is obviously the major one on this…