¶ 39. (dissenting). I respectfully dissent. The majority opinion broadly authorizes recovery of mental health treatment expenses in a claim for tortious interference with contract. It does so in a case in which no damages for mental distress were proven, and, indeed, no other compensatory damages of any kind were awarded against the defendant. This is contrary to the law governing recovery of emotional *344distress damages in the intentional tort context, as outlined in Anderson v. Continental Insurance Co., 85 Wis. 2d 675, 271 N.W.2d 368 (1978).
¶ 40. The jury in this case found that defendant Buelow tortiously interfered with plaintiff Musa's prospective contract regarding the sale of a hotel. The jury did not, however, award any pecuniary (loss of contract benefits) or emotional distress damages against Buelow. Instead, it awarded an amount corresponding to Musa's mental health treatment expenses — $4,000—as consequential damages, plus $50,000 in punitive damages. The circuit court set aside the mental health treatment damages as unforeseeable and unsupported by any pecuniary damages. The circuit court then eliminated the punitive damages award since there were no longer any compensatory damages to support it. The court of appeals affirmed based upon Anderson.
¶ 41. In Anderson, this court recognized the tort of bad faith refusal to honor an insurance claim. In doing so, the court acknowledged the risks associated with the creation of a tort in the contract context, in particular, the danger of expanding the categories of allowable damages, since tort law is more liberal than contract as far as the types of recoverable damages are concerned. As a result, the court took pains to specify the rules of limitation applicable to recovery of damages for emotional injury in tort:
It is apparent. . .that another aspect of the in terrorem nature of an action for bad faith arises because it is an intentional tort. Intentional torts may in some circumstances result in not only compensatory damages, but also punitive damages and damages for emotional injury....
*345Some generalities in respect to damages for mental distress.. .are.. .[therefore] appropriate.
In negligent torts, mental distress is compensa-ble only when there is an accompanying or resulting physical injury. Ver Hagen v. Gibbons, 47 Wis. 2d 220, 177 N.W.2d 83 (1970). In intentional torts, substantial other damages in addition to damages for emotional distress are required. D.R.W. Corp. v. Cordes, 65 Wis. 2d 303, 222 N.W.2d 671 (1974). Where the tort is specifically that of the intentional infliction of emotional distress, no other damages need be alleged or proved. However, additional limitations are imposed on a cause of action for the intentional infliction of emotional distress. A plaintiff must prove that the purpose of the conduct was to cause emotional distress, that the conduct was extreme and outrageous, that it was the cause in fact of the plaintiff s injury, and that the plaintiff suffered an extreme disabling emotional response. McKissick v. Schroeder, 70 Wis. 2d 825, 832, 235 N.W.2d 686 (1975); Alsteen v. Gehl, 21 Wis. 2d 349, 124 N.W.2d 312 (1963).
[T]he tort of bad faith falls within the second category described above, where substantial other damages in addition to the emotional distress are required if there is to be recovery for damages resulting from the infliction of emotional distress. In the bad faith cause of action against an insurance company, we therefore conclude that to recover for emotional distress. . .the plaintiff must plead and prove substantial damages aside and apart from the emotional distress itself and the damages occasioned by the simple breach of contract.
We [further] conclude. . .consistent with. . .McKissick and Alsteen, supra, that in no *346circumstances may a plaintiff recover for emotional distress, even when there are other accompanying damages, unless the emotional distress is severe. A recovery for emotional distress caused by an insurer's bad faith refusal to pay an insured's claim should be allowed only when the distress is severe and substantial other damage is suffered apart from the loss of the contract benefits and the emotional distress.
Anderson, 85 Wis. 2d at 694-96 (emphasis supplied).
¶ 42. I have quoted at some length from the Anderson opinion because I think the majority has strayed far from the rules it established for recovery of damages for emotional injury in an intentional tort claim. The substantial other damages requirement, and the requirement that the emotional injury be severe in order to be recoverable, exist to preclude recovery for insignificant, questionable, or feigned emotional injuries associated with intentional torts that otherwise have nothing to do with emotional distress or injury. Where the tort arises in the contract setting, the substantial other damages requirement is also a necessary bulwark against the wholesale erosion of the border between contract and tort law remedies.
¶ 43. The majority acknowledges that Anderson's substantial other damages rule was extended to tortious interference with contract claims in Bauer v. Murphy, 191 Wis. 2d 517, 534-35, 530 N.W.2d 1 (Ct. App. 1995). The majority does not overrule Anderson or Bauer, or otherwise circumscribe their application. Rather, the majority simply treats the mental health expenses award in this case as a routine medical and hospital special damages award, as if this were a garden-variety personal injury case instead of a tortious interference with contract claim. In other words, the *347majority characterizes the $4,000 mental health treatment award against Buelow as something somehow unconnected to an award for emotional injury. This characterization takes the award outside the confines of Anderson and Bauer altogether, thus avoiding the requirement of substantial other damages to support it.
¶ 44. This cuts the heart out of the substantial other damages requirement, clearing the way for the sorts of questionable emotional injury claims in intentional tort lawsuits that Anderson specifically sought to avoid. The majority states that "no Wisconsin court has ever held that emotional distress is a prerequisite to recovery of mental health care expenses." Majority op. at ¶ 23. Perhaps this is because the premise seems fairly self-evident. How can mental health treatment expenses be legally recoverable if there is no compensa-ble mental distress in the first place? This is not comparable to recovery of medical and hospital expenses in the absence of an award for pain and suffering in a personal injury action, for the simple reason that this is not a personal injury action. This is an economic tort, and the law specifies some limits on the recovery of damages for emotional injuries in this context.
¶ 45. The important prerequisite here is that set forth in Anderson: before any damages for emotional injury can be recovered in an intentional tort that does not have the infliction of emotional distress as its gravamen, there must be substantial other damage, proof of some significant harm stemming from the tort that is separate and apart from any claimed emotional injury. If there is such harm, then the law will recognize a collateral, causal emotional injury, assuming it is sevqre, as legitimate and compensable. If there is not, *348then the law will not allow recovery of damages related to emotional distress, on the theory that if the tortious conduct has caused no (or insubstantial) damage, then any emotional reaction to it does not deserve to be compensated.
¶ 46. And clearly, any expense incurred to treat emotional distress cannot itself satisfy the substantial other damages requirement. Anderson requires that the substantial other damages must be separate and apart from any damages attributable to emotional distress.
¶ 47. The court of appeals' decision in this case was not so much an extension of Anderson as a straightforward application of its principles. I agree with its analysis. The $4,000 consequential damages award against Buelow was properly set aside as unsupported by substantial other damages. This leaves the punitive damages award unanchored to any compensatory damages, and it too was properly set aside. See Tucker v. Marcus, 142 Wis. 2d 426, 431, 418 N.W.2d 818 (1988).1 Accordingly, I would affirm the court of appeals.
¶ 48. I am authorized to state that Justice JON P. WILCOX joins this dissenting opinion.
Musa argues in the alternative that the pecuniary damages award against Jefferson County Bank, Buelow's employer, should be sufficient to sustain the punitive damages award against Buelow. There is no authority for permitting a compensatory damages award against one defendant to support a punitive damages award against another.