You may recall a more recent example.  In early 2001, police discovered hundreds of decomposed bodies stacked in storage sheds and scattered in the woods in Noble, Georgia, northwest of Atlanta.  The remains were to have been cremated by the Tri-State Crematory, a business that dealt with 25 to 30 funeral directors in Georgia, Tennessee and Alabama. Ray Brent Marsh, the owner and operator of the crematorium, claimed that the incinerator had not been working and that there were insufficient funds to repair it.  In January 2005, Marsh was sentenced to 12 years in prison, a $20,000 fine, and lengthy probation following prison pursuant to a plea bargain with Georgia prosecutors in which he pled guilty to 787 counts, including for theft, abuse of a corpse, burial service fraud, and making false statements.  Marsh also pled guilty to related charges in Tennessee for which he also received a 12-year prison sentence to run concurrently with the Georgia prison sentence. 

     In addition to compensatory damages for emotional distress, should a court treat the crematorium's breaches of contract as torts and permit punitive damages?  See the concurring and dissenting opinion of Justice Mosk in Freeman & Mills, Inc. v. Belcher Oil Co.   Note that while a debt representing damages for breach of contract is typically dischargeable in a bankruptcy, a debt representing damages for "wilful and malicious injury" to another person may not be discharged in bankruptcy.  11 U.S.C. 523(a)(6). 

     Marsh reached a civil settlement for $80 million dollars with relatives of those who died.  I imagine but don't know that the plaintiffs asserted both contract and tort theories in the lawsuit.  It seems unlikely that Marsh will ever be able to pay much of the settlement amount.  Relatives of those who died also sued funeral homes that sent bodies to Marsh's crematory.  The funeral homes settled those lawsuits for $36 million, much of which has been paid.