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No-fault engagement rings: Court decides you have to return the ring if you break up before the wedding and your former heartthrob asks for it back

The Supreme Judicial Court today broke with earlier case law and declared that engagement rings have to be returned on request in the event of a pre-marriage breakup regardless of who might be at fault in the parting of ways.

Up until the ruling, Massachusetts residents who had been given engagement rings for marriages that never happened only if a court determined the person asking for the ring was "without fault."

But now, in deciding the case of a Plymouth County ex-couple, Bruce Johnson and Caroline Settino, and the $70,000 engagement ring and a $3,5000 wedding band the former gave the latter, the court said it was joining Massachusetts with other states in concluding "the engagement ring must be returned to the donor regardless of fault." At the same time, the court ordered Johnson to pay Settino interest for the two-step dental-implant surgery for which he paid only for the first part - having her front teeth removed - before they broke up.

The court summarized the events leading to their engagement and then parting of ways, after they met in 2016 and began dating:

Over the next year, they traveled together, visiting New York, Bar Harbor, the Virgin Islands, and Italy. Johnson paid for these vacations, expecting nothing in return. Johnson also showered Settino with lavish gifts of jewelry, clothing, shoes, and handbags. It was customary for Johnson to give Settino the receipts for these gifts.

The couple selected a $70,000 engagement ring - and Johnson paid for Settino to have her upper front teeth removed to be replaced by implants. But the couple began to bicker and one night, after an argument, when Settino stormed out of the room but left her phone behind, Johnson began scrolling through her text messages and found an exchange with man in Connecticut that sounded like they were arranging an assignation while Johnson was out of town.

Johnson, already troubled by the arguing, called off the wedding plans, asked for the ring back - and refused to pay for Settino to have the implants put in to replace the teeth she'd had pulled.

She refused to give the ring back and he sued. A Plymouth Superior Court judge ruled in her favor, saying that the evidence suggested the guy in Connecticut really was just an old friend, like Settino claimed and because there was no proof of a dailliance, Settino played no role in the breakup and the decision was solely Johnson's and therefore, Johnson was the one to blame for it and so he couldn't get the ring.

The Massachusetts Appeals Court last year ordered her to replace the ring and him to pay interest on the teeth replacement, but was careful to say it was deciding only on the merits of this one case, not setting a precedent, because that's something only the SJC, the state's highest court, can do.

Today, the SJC said it was setting precedent and bringing the issue of engagement breakups both in line with modern thinking on relationships and with the state's existing "heart balm" law, which bars using the courts to settle romantic disputes. Until today, the precedent in Massachusetts was that disputes over rings before a wedding were not romantic disputes, but contract ones not necessarily subject to that law.

The court cited several factors, including the fact that post-marriage breakups, a.k.a., divorces, in Massachusetts are now no fault and that, honestly, how in the world is a judge truly to decide who is at fault in matters of the heart, as had been required under a case decided 60 years ago?

The court cited one New Jersey decision:

What fact justifies the breaking of an engagement? The absence of a sense of humor? Differing musical tastes? Differing political views?

And the justices cited a Pennsylvania ruling:

It is unlikely that trial courts would be presented with situations where fault was clear and easily ascertained.

Also, the court concluded, part of the point of an engagement is for a couple to see if they are truly compatible for marriage:

[C]ourts have remarked that assigning blame to one who breaks an engagement is at odds with a principal purpose of the engagement period to allow a couple time to test the permanency of their wish to marry.

And so, the court concluded, it's time to take the rare judicial step of breaking with precedent and setting out a new legal path:

As a result of these considerations, the modern trend, and now majority view among courts that have considered this issue, is that the only relevant inquiry in conditional engagement gift cases is whether the condition under which the gift was made -- that is, the marriage ceremony -- has failed to occur. Where the planned nuptial does not come to pass, the engagement gift must be returned to the donor.

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Comments

Inferring an implicit legal contract where none was ever signed seems like an awfully slippery slope, and I hope the opinion here was written in a way that keeps this logic from being cited in other contexts. Whether or not something is a gift ought to be settled at the time of the giving and not something that can be altered retroactively.

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Voting closed 10

In nearly every state, engagement rings fall under their own category of gifts where they are gifted conditionally. The change to the ruling here moves Massachusetts from a "at fault" to a "no fault" return of the ring. It means the ring is returned even if the person who calls off the wedding is the giftee. This is in line with all other states besides Alabama, Alaska, Kentucky, and New Hampshire. The only other exception is Montana where the ring is gifted unconditionally.

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Voting closed 30

Hope he learned a lesson.

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Voting closed 21

Why don't you come back in a few years when you've matured. It's bad enough that we have to put up with Magoo's nonsense, but we don't need the level of maturity here dragged down by anyone who thinks a comment like this is worthwhile of the UHub discourse.

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Voting closed 19

what it deserves

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Voting closed 14

This wonderful former couple might be reading this and you'll look rude.
/s

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Voting closed 5

you give the ring back unless it was given as a gift, for example a Christmas gift or a Valentine's Day gift. Engagement rings are not given unconditionally. They are given with the understanding that you will get married.

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Voting closed 31

The Massachusetts Appeals Court heard this on March 1, 2023. The arguments are posted on YouTube for anyone interested. Starts at 1:29:33 ends at 2:00:39 (apparently each side gets 15 minutes).
Youtube: Mass Appeals Court

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Voting closed 11

« My Bruce is going to be in Connecticut for three days. I need some playtime. »

Yeah, that would only be innocuous in a poly relationship, which this was not.

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Voting closed 8

n/t

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Voting closed 4