In Kirksey v. Jernigan, 45 So. 2d 188 (Fla. 1950), the plaintiff sought compensatory and punitive damages for mental pain and anguish for the wrongful withholding and handling of her child's dead body under a scenario in which there was, again, no physical impact to the claimant. See id. at 189. The Court reaffirmed a "commitment to the rule . . . that there can be no recovery for mental pain and anguish unconnected with physical injury in an action arising out of the negligent breach of a contract whereby simple negligence is involved." Id. at 189. However, the Court recognized an exception for cases involving outrageous or intentional conduct, declining to "extend this rule to cases founded purely in tort, where the wrongful act is such as to reasonably imply malice, or where, from the entire want of care of attention to duty, or great indifference to the persons, property, or rights of others, such malice will be imputed as would justify the assessment of exemplary or punitive damages." Id. The Court concluded that the facts in Kirksey satisfied this standard and reversed the lower court's entry of final judgment on demurrer in favor of the defendant. See id. at 190.