[711]*711LINDE, J.
Plaintiff and defendants are cattle buyers. When plaintiff contracted to buy 550 head of steers from a third person for immediate resale, defendants caused the seller to breach this contract by buying the same cattle at a higher price, leaving plaintiff for a time unable to deliver cattle to his buyer. Plaintiff brought action for interference with his purchase contract, seeking damages for loss of reputation and for mental anguish suffered as “a direct and proximate result” of defendant’s interference, as well as punitive damages. A jury awarded plaintiff $6,500 damages for mental anguish only.
The Court of Appeals reversed, holding that interference with contractual relations is not one of the torts in which damages for mental suffering may be awarded in the absence of physical injury. 49 Or App 959, 621 P2d 93 (1980). We allowed review to consider the right to such damages in a tort action for inducing breach of contract.
Upon examination, the question proves to be far from settled. There are more assertions in the secondary commentary than actual decisions from which a general rule may be drawn. In England, it is said that the “primary protection afforded by the tort ushered in by Lumley v. Gye,1 is against business losses: “business men cannot complain of injured feelings alone.” Mayne & McGregor on Damages § 943 (12th ed 1961). Another text of the same vintage, to the contrary, states that a plaintiff “will often receive greater damages in tort” than for the breach of contract; “he can obtain exemplary damages, invoke the rule that intentionally caused damages are recoverable for an intentional tort, and obtain damages for loss of reputation and injured feelings.” Street, Principles of the Law of Damages 252 (1962). Neither work cites authority for either proposition.2 As to American law, Sedgwick stated in [712]*712a single sentence that “for maliciously procuring the breach of any contract the measure of damages is ordinarily the same as it would be in an action for breach of the contract itself.” 2 Sedgwick on Damages § 470a at 900 (2nd ed 1912).3 A more detailed student note in 1930 reported that some courts deemed the contract rule to be the proper measure of tort * damages for inducing a breach,4 while others stated that the tort defendant was liable for all resulting damages, by analogy to damages for intentional interference with tangible property, and a third group applied a “proximate” injuries rule comparable to that in negligence cases. Note, Damages Recoverable in an Action for Inducing Breach of Contract, 30 Col L Rev 232 (1930). Many of the early cases involved interference with plaintiffs employment, and in that setting Massachusetts decisions allowed recovery for “injured feelings,” Gould v. Kraemer, 253 Mass 433, 440, 149 NE 142 (1925), Doucette v. Salinger, 228 Mass 444, 117 NE 897 (1917), or reputation, DeMinico v. Craig, 207 Mass 593, 94 NE 317 [713]*713(1911). The note reported only a few other decisions on either side of that issue. 30 Col L Rev at 237, n. 27.
More recently, Dean Prosser briefly repeated the same classification, adding a few more recent citations but none on the issue of recovery for mental anxiety or distress. Prosser’s own preference was for the measure of damages common to other intentional torts to persons or property. Prosser, Law of Torts § 129, at 948-949 (4th ed 1971). His position was adopted by a California appellate court in Duff v. Engelberg, 237 Cal App 2d 505, 47 Cal Rptr 114 (1965), in which defendants motivated by racial prejudice had caused a seller to renege on a contract to sell a residence to plaintiffs. Professor Dobbs’s treatment of the law of damages states that damages for mental suffering, loss of reputation, and punitive damages, though normally not available for breach of contract, “are pretty well accepted as recoverable against the tortious inducer of that breach”; however, the statement is not supported by any citations. Dobbs, Remedies § 6.4, at 463 (1973). A number of other commentators have reviewed the three different measures of damages drawn from actions for breach of contract, intentional torts, and negligence without adding much information on the subject of mental or emotional distress. See Developments in the Law-Competitive Torts, 77 Harv L Rev 888, 967-969 (1964); Note, Interference with Contractual Relations in New England, 38 B U L Rev 285 (1958); Comment, Interference, With Contractual Relations: A Common Measure of Damages, 7 Santa Clara Law Rev 140 (1966).
The original Restatement of Torts, in section 766, stated that one who purposely causes a third person not to perform a contract with another “is liable to the other for the harm caused thereby.” The quoted phrase appeared to measure the range of liability entirely by causation in fact, but the comments to section 766 said nothing further on the issue of damages. The Restatement of Torts (Second) added a new section 774A which states that the damages recoverable in an action for interference with contractual relation include the pecuniary loss of the benefits of the contract, other consequential losses, and “emotional distress or actual harm to reputation, if they are reasonably to be [714]*714expected to result from the interference.”5 The record of the adoption of this statement by the American Law Institute, however, reflects no great conviction that it is a “restatement” of an established rule.6 In sum, the state of the authorities encourages us to examine the question anew.
Search for a principle may take its starting point either in the decisions allowing or denying damages for mental distress in other tort actions, or in a narrower focus on the characteristics of the interference tort. Taking the first tack, defendants brief Douglas v. Humble Oil, 251 Or 310, 445 P2d 590 (1968), in which the torts were a trespass to a home and conversion of personal property, Fredeen v. Stride, 269 Or 369, 525 P2d 166 (1974), which involved a veterinarian’s conversion of a dog, and Edwards v. Talent [715]*715Irrigation District, 280 Or 307, 570 P2d 1169 (1977), a case of negligent flooding of land. From these they argue the general propositions that damages are allowed for mental distress only when this distress is a direct and predictable result accompanying a tangible injury, or aggravated by the quality of defendant’s wrongful conduct, and that without a physical injury to person or property only a few torts are specifically designed to recognize emotional injuries, such as invasion of privacy, see Hinish v. Meier & Frank Co., 166 Or 482, 113 P2d 438 (1941) or intentional infliction of emotional distress, as in Turman v. Central Billing Bureau, 279 Or 443, 568 P2d 1382 (1977). The Court of Appeals thought itself bound to reverse the award of damages for mental distress by what was said in these cases and in Melton v. Allen, 282 Or 731, 580 P2d 1019 (1978), which denied such damages for a trespass to plaintiffs automobile.7
These and other cases may have left some question about the significance of various factors to liability for mental distress, for instance whether this liability results from defendant’s intent, as distinguished from recklessness or negligence, compare Melton, supra, with
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[711]*711LINDE, J.
Plaintiff and defendants are cattle buyers. When plaintiff contracted to buy 550 head of steers from a third person for immediate resale, defendants caused the seller to breach this contract by buying the same cattle at a higher price, leaving plaintiff for a time unable to deliver cattle to his buyer. Plaintiff brought action for interference with his purchase contract, seeking damages for loss of reputation and for mental anguish suffered as “a direct and proximate result” of defendant’s interference, as well as punitive damages. A jury awarded plaintiff $6,500 damages for mental anguish only.
The Court of Appeals reversed, holding that interference with contractual relations is not one of the torts in which damages for mental suffering may be awarded in the absence of physical injury. 49 Or App 959, 621 P2d 93 (1980). We allowed review to consider the right to such damages in a tort action for inducing breach of contract.
Upon examination, the question proves to be far from settled. There are more assertions in the secondary commentary than actual decisions from which a general rule may be drawn. In England, it is said that the “primary protection afforded by the tort ushered in by Lumley v. Gye,1 is against business losses: “business men cannot complain of injured feelings alone.” Mayne & McGregor on Damages § 943 (12th ed 1961). Another text of the same vintage, to the contrary, states that a plaintiff “will often receive greater damages in tort” than for the breach of contract; “he can obtain exemplary damages, invoke the rule that intentionally caused damages are recoverable for an intentional tort, and obtain damages for loss of reputation and injured feelings.” Street, Principles of the Law of Damages 252 (1962). Neither work cites authority for either proposition.2 As to American law, Sedgwick stated in [712]*712a single sentence that “for maliciously procuring the breach of any contract the measure of damages is ordinarily the same as it would be in an action for breach of the contract itself.” 2 Sedgwick on Damages § 470a at 900 (2nd ed 1912).3 A more detailed student note in 1930 reported that some courts deemed the contract rule to be the proper measure of tort * damages for inducing a breach,4 while others stated that the tort defendant was liable for all resulting damages, by analogy to damages for intentional interference with tangible property, and a third group applied a “proximate” injuries rule comparable to that in negligence cases. Note, Damages Recoverable in an Action for Inducing Breach of Contract, 30 Col L Rev 232 (1930). Many of the early cases involved interference with plaintiffs employment, and in that setting Massachusetts decisions allowed recovery for “injured feelings,” Gould v. Kraemer, 253 Mass 433, 440, 149 NE 142 (1925), Doucette v. Salinger, 228 Mass 444, 117 NE 897 (1917), or reputation, DeMinico v. Craig, 207 Mass 593, 94 NE 317 [713]*713(1911). The note reported only a few other decisions on either side of that issue. 30 Col L Rev at 237, n. 27.
More recently, Dean Prosser briefly repeated the same classification, adding a few more recent citations but none on the issue of recovery for mental anxiety or distress. Prosser’s own preference was for the measure of damages common to other intentional torts to persons or property. Prosser, Law of Torts § 129, at 948-949 (4th ed 1971). His position was adopted by a California appellate court in Duff v. Engelberg, 237 Cal App 2d 505, 47 Cal Rptr 114 (1965), in which defendants motivated by racial prejudice had caused a seller to renege on a contract to sell a residence to plaintiffs. Professor Dobbs’s treatment of the law of damages states that damages for mental suffering, loss of reputation, and punitive damages, though normally not available for breach of contract, “are pretty well accepted as recoverable against the tortious inducer of that breach”; however, the statement is not supported by any citations. Dobbs, Remedies § 6.4, at 463 (1973). A number of other commentators have reviewed the three different measures of damages drawn from actions for breach of contract, intentional torts, and negligence without adding much information on the subject of mental or emotional distress. See Developments in the Law-Competitive Torts, 77 Harv L Rev 888, 967-969 (1964); Note, Interference with Contractual Relations in New England, 38 B U L Rev 285 (1958); Comment, Interference, With Contractual Relations: A Common Measure of Damages, 7 Santa Clara Law Rev 140 (1966).
The original Restatement of Torts, in section 766, stated that one who purposely causes a third person not to perform a contract with another “is liable to the other for the harm caused thereby.” The quoted phrase appeared to measure the range of liability entirely by causation in fact, but the comments to section 766 said nothing further on the issue of damages. The Restatement of Torts (Second) added a new section 774A which states that the damages recoverable in an action for interference with contractual relation include the pecuniary loss of the benefits of the contract, other consequential losses, and “emotional distress or actual harm to reputation, if they are reasonably to be [714]*714expected to result from the interference.”5 The record of the adoption of this statement by the American Law Institute, however, reflects no great conviction that it is a “restatement” of an established rule.6 In sum, the state of the authorities encourages us to examine the question anew.
Search for a principle may take its starting point either in the decisions allowing or denying damages for mental distress in other tort actions, or in a narrower focus on the characteristics of the interference tort. Taking the first tack, defendants brief Douglas v. Humble Oil, 251 Or 310, 445 P2d 590 (1968), in which the torts were a trespass to a home and conversion of personal property, Fredeen v. Stride, 269 Or 369, 525 P2d 166 (1974), which involved a veterinarian’s conversion of a dog, and Edwards v. Talent [715]*715Irrigation District, 280 Or 307, 570 P2d 1169 (1977), a case of negligent flooding of land. From these they argue the general propositions that damages are allowed for mental distress only when this distress is a direct and predictable result accompanying a tangible injury, or aggravated by the quality of defendant’s wrongful conduct, and that without a physical injury to person or property only a few torts are specifically designed to recognize emotional injuries, such as invasion of privacy, see Hinish v. Meier & Frank Co., 166 Or 482, 113 P2d 438 (1941) or intentional infliction of emotional distress, as in Turman v. Central Billing Bureau, 279 Or 443, 568 P2d 1382 (1977). The Court of Appeals thought itself bound to reverse the award of damages for mental distress by what was said in these cases and in Melton v. Allen, 282 Or 731, 580 P2d 1019 (1978), which denied such damages for a trespass to plaintiffs automobile.7
These and other cases may have left some question about the significance of various factors to liability for mental distress, for instance whether this liability results from defendant’s intent, as distinguished from recklessness or negligence, compare Melton, supra, with McEvoy v. Helikson, 277 Or 781, 562 P2d 540 (1977), or from the “direct and natural” causation, that is to say predictability, of the mental distress, see Fredeen v. Stride, supra, and Douglas v. Humble Oil, supra, and whether “aggravated circumstances” are relevant to liability for such distress [716]*716because of defendant’s greater culpability for acts of “a flagrant character,” Melton v. Allen, supra, or because defendant’s “aggravated conduct” contributes “evidence of genuine emotional damage,” Fredeen v. Stride, supra. As the court stated in Edwards, “[t]he law involving recovery for emotional distress generally is confused and perhaps in need of rethinking by the courts.” 280 Or at 310, n. 4.
The concept of “tort” is vulnerable to this confusion because the one word is used to encompass both the defendant’s wrong and the injury entitling plaintiff to redress. When the focus is on defendant’s conduct, an intentional wrongdoer often seems more deserving of liability than a careless or innocent one. From the plaintiffs perspective, the injury that the defendant has caused may be equally severe in either event, unless plaintiffs knowledge of defendant’s attitude in fact magnifies plaintiffs distress. Nevertheless, as in some formulations of recovery for mental distress from trespass or conversion, the double focus sometimes leads to carrying the factor of defendant’s culpability from the definition of the tort into the measure of plaintiffs damages as well. See Restatement of Torts, § 927, Comment 1, quoted in Fredeen v. Stride, supra.8 As already stated, however, the formula actually employed in that decision and in Douglas v. Humble Oil, supra, rested the inclusion or exclusion of damages for mental distress not on the defendant’s motives but on whether such distress was a common and predictable result under the circumstances of the kind of conversion involved. In the tort of interference with another’s contract, the defendant’s knowledge and intent are required elements of the tort itself. See American Sanitary Service v. Walker, 276 Or 389, 394, 554 P2d 1010 (1976), Wampler v. Palmerton, 250 Or 65, 73, 439 P2d 601 (1968).9 The question is whether it follows that the liability for damages to which it gives rise necessarily is the same as in other intentional torts.
[717]*717The court appeared to adopt that position in Wampler v. Palmerton, supra, although it reached no holding on damages, because the court concluded that no tort had been proved. In the course of an introductory review of the interference tort, the opinion stated:
“The relief granted is of the broad type available in intentional tort actions and includes recompense for mental suffering, damage to reputation, and punitive damages. It therefore affords the relief which would have been recoverable from the party breaching the contract and also for the less tangible personal harms such as those sought in the instant case.” (Footnotes omitted.)
250 Or at 73. This passage, however, must be read in its context. It was preceded by a discussion of the expansion of the tort from interference with employment, as in Lumley v. Gye, supra, to other contractual relationships.
“The interest protected by the interference with contract action is the interest of the individual in the security and integrity of the contractual relations into which he has entered. Economic relations are controlled by contract and the public also has an interest in maintaining the security of such transactions. Therefore the law provides protection.” (Footnotes omitted.)
Id. at 73. Commercial or economic interests, of course, are only one kind of interest secured by the protection that the law affords to contractual relations. They are the kind involved in Wampler and in this case. The interest in one’s occupation, as in the Massachusetts cases previously cited, or in one’s choice of a home, as in Duff v. Engelberg, supra, often goes beyond the merely economic interest in regular wages or in an advantageous price to include such noneconomic values as personal associations, love of a place, and pride in one’s work that add up to one’s sense of identity.
We think, therefore, that recovery of damages beyond pecuniary loss from interference with a contract does not depend only on the presence of intentional interference for an improper objective or by wrongful means, along with causation. See Top Service Body Shop v. Allstate Ins., Co., 283 Or 201, 582 P2d 1365 (1978). Damages for noneconomic injury depend also on what kind of contractual arrangement is disrupted by defendant and how the claimed injury [718]*718relates to that kind of arrangement. The mental distress, injured reputation, or other consequential harm not only must have occurred, and have resulted from defendant’s interference, it also must have been an injury of a kind that should have been expected as a common and predictable accompaniment of disrupting the type of relationship with which the defendant interfered.10
This analysis corresponds to the rule formulated in the Restatement with one qualification. To recover either for emotional distress or for harm to reputation in an action for interference with contractual relations, injury of that kind must be a common and predictable result of disrupting the type of relationship or transaction involved rather than a result “reasonably to be expected” in the particular situation, as seems to be the import of section 774(A)(1)(c), supra, n. 5. The defendant’s wrong is intentional, not a default of foresight. There are many kinds of contractual relations, however, just as there are many different settings for trespass or conversion. Compare Douglas and Fredeen, supra, with Hall v. Work, 223 Or 347, 354 P2d 837 (1960). The claimed injury must be typical of the kind of contractual relationship involved in the case in order to come within the interests that the tort duty of noninterference is designed to protect, whatever other theory of recovery may also be available to the injured party.
As already stated, these typical interests can differ when the disrupted relationship is employment, or a consumer purchase of a particular home or unique chattel, or a commercial transaction between entrepreneurs, or perhaps a wholly nonfinancial agreement. For instance, when the tort is applied in order to secure contractual arrangements [719]*719and opportunities in the general economy, mental or emotional distress will not be a characteristic result of interference between corporate enterprises. The same may or may not be true of business dealings characteristically carried on by individuals.
It can be argued that in ordinary commercial dealings even among individuals, the tort is designed to protect only business interests — the purely economic interests of Adam Smith’s abstract “economic man” who, as suggested in Mayne & McGregor, supra, “cannot complain of injured feelings alone.” Upon consideration, we reject that view. Commerce is too broad a category to sweep all kinds of transactions under a single rule protecting only pecuniary interests against an outsider’s wrongful interference. Established customs and expectations may vary in one economic sector from those in an entirely different one. The loss of some fraction of all deals, whether induced by a competitor or by other intermeddling, may be a common experience in some branches of business, though the plaintiff in the particular case tends to become upset. In other branches, such interference may universally be recognized as a rare breach of custom and a predictable source of shock and dismay. Again, mental distress has been included in damages for interference with one’s employment; but too many crafts and trades rely on independent contracts as well as on contracts of employment, and the distinction is too tangential to the likelihood of anxiety and distress, to allow recovery for such consequences when the interference is with employment but exclude it for interference with business contracts as a matter of law. Rather, it remains open to show that they are common and predictable consequences of such interference in the type of business setting involved.
Even when serious anxiety and frustration are typical and predictable effects of disruptive interference in a business setting, however, damages are confined to those effects. Recovery extends only to the mental or emotional distress involved in dealing with the disruption itself. By this test, the stress of finding another buyer or source of supply, of restoring confidence in the future performance of the business, or in case of more fatal interference, of selling or liquidating the enterprise could give rise to damages; [720]*720distress at personal consequences such as a sacrificed vacation, financial stringency, or family stresses would not.
In this case the applicable rule was discussed at length in the course of argument on defendant’s motion for dismissal at the conclusion of plaintiffs case (more accurately a motion for directed verdict, ORCP 60), and on their motion for judgment notwithstanding the verdict. The trial court concluded that contractual interference is not the kind of tort in which “as a matter of law” there is such likelihood of emotional distress that the jury can be instructed to include it in an award of general damages, but rather that the instructions would be that a higher standard of proof would be required. The instructions actually given were not challenged on appeal and are not before us. Neither does the appeal present an issue concerning the adequacy of evidence whether nonpecuniary injuries typically can be expected to result from interfering with contracts between cattle dealers. Rather, defendants argue that even assuming that damages for mental distress resulting from interference with a contract could be allowed at all, there was insufficient evidence of “aggravated conduct” by defendants to justify submitting plaintiffs claim for such damages to the jury.
Under the test we have set forth in this opinion, recovery for mental distress in this tort hinges on factors other than the degree of defendant’s culpability. Because we have concluded that the Court of Appeals was mistaken about the requirements for such an award of damages, and no other issue is presented concerning the application of the correct rule to the facts in this case, the decision of the Court of Appeals must be reversed and the judgment on the jury’s verdict reinstated.
Reversed.