State High Court Adopts Modern Standard for Who Keeps $70K Engagement Ring After Breakup
"We now join the modern trend adopted by the majority of jurisdictions that have considered the issue and retire the concept of fault in this context; where, as here, the planned wedding does not ensue and the engagement is ended, the engagement ring must be returned to the donor regardless of fault," Associate Justice Dalila Argaez Wendlandt wrote on behalf of the Massachusetts court.
November 11, 2024 at 01:47 PM
4 minute read
Ending a 65-year standard of who keeps the engagement ring if a wedding is called off, Massachusetts' top court concluded that a would-be bride should return a $70,000 engagement ring regardless of "fault."
On Friday, the Massachusetts Supreme Judicial Court unanimously retired the decades-old holding in DeCicco v. Barker, which recognized an engagement ring as a conditional gift that may be recovered by the donor as long as the donor was "without fault" for ending the engagement. The high court's ruling in Johnson v. Settino reversed a portion of the judgment that awarded Caroline Settino the six-carat Tiffany & Co. engagement ring and wedding band after her fiance, Bruce Johnson, ended their relationship.
In part, the court analyzed whether Johnson was "at fault" for calling off the wedding after mistakenly accusing Settino of having an affair. A fight ensued over who got to keep the pricey engagement ring and two wedding bands that cost approximately $3,700, according to the opinion.
"We now join the modern trend adopted by the majority of jurisdictions that have considered the issue and retire the concept of fault in this context; where, as here, the planned wedding does not ensue and the engagement is ended, the engagement ring must be returned to the donor regardless of fault," Associate Justice Dalila Argaez Wendlandt wrote on behalf of the court.
The "no fault" approach been adopted by states such as Indiana, Iowa, Kansas, Michigan, Minnesota, New Jersey, New York, Ohio, Tennessee and others. The courts generally view the ring as a conditional gift that must be returned to the donor if the engagement is terminated, regardless of who was responsible for the prenuptial breakup.
Johnson's attorney, Stephanie Taverna Siden, a parter at Siden & Associates in Boston, said she and her client are pleased with the court's ruling.
"It is well-reasoned, fair and moves Massachusetts law in the right direction," Siden told Law.com.
The Massachusetts high court rejected Settino's push to toss the conclusion in DeCicco that the engagement ring is a conditional gift given on the implied condition that the marriage will happen, the opinion said.
"Unlike the persusaive analysis from our sister courts regarding the unworkability of a fault-based approach to engagement gifts, on the record before us, the case for reconsidering the conditional gift aspect of our decision in De Cicco falls flat," Wendlandt said.
Nicholas J. Rosenberg, a Boston attorney at Gardner & Rosenberg who represented Settino, said that he was pleased that Massachusetts has modernized by adopting the no-fault approach.
However, he told Law.com that he was "disappointed with the retention of the societal presumption that a ring is given conditionally and not fully vested unless the recipient completes the promise of marriage," he said.
"We firmly believe that the idea of an engagement ring as a conditional gift is predicated on outdated notions," Rosenberg said. "It is otherwise well-established that a breach of a promise to marry is not an injury recognized by law, and rings should be no different. We nonetheless recognize and respect the court’s decision to follow the majority rule among the states."
Plymouth Superior Court Judge Brian S. Glenny found that Johnson was at fault for the parties' separation because he was mistaken about his claims of infidelity. In Johnson's attempt to recover the rings, the trial court awarded the jewelry to Settino.
In a divided Massachusetts Appeals Court ruling, the majority reached a "fault" assessment and that Johnson was not "at fault" because his actions were reasonable under the circumstances. The panel said appellate courts in the commonwealth had yet to address fault and who kept the conditional engagement gift, according to the opinion.
The state high court said assessing blame when one party cancels the forthcoming nuptials is at odds with the principal purpose of an engagement period, which is to "test the permanency of the couple's wish to marry," and counters public policy, including Massachusetts' "heart balm act." Additionally, the Legislature has adopted no-fault divorce to tailor it to modern relationships.
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