Maffe v. Loranger - No. CV196108439S, 2021 Conn. Super. LEXIS 67 (Super. Ct. Jan. 28, 2021)

Rule:

With respect to engagement rings specifically, older superior court cases from Connecticut applied what is known as a fault standard, finding that the court would look at which party was at fault for the parties' failure to marry. The modern view (no-fault standard) is that the gift of the engagement ring is a conditional gift, the condition being the subsequent marriage of the parties. If the marriage does not take place, the condition has not been met and the ring should be returned to the donor. However, even applying the no-fault modern view, determining which party is entitled to the ring when the parties fail to marry depends on the specific facts of the case.

Facts:

The plaintiff brought this action to recover the engagement ring he presented to the defendant former fiancée when he proposed marriage. The plaintiff claimed that the engagement ring was a conditional gift—the condition being the fulfillment of the promise that the parties get legally married. Because the couple ended their relationship and did not marry, the plaintiff claimed that the defendant must return the ring to him. As a special defense, the defendant claimed that even if the engagement ring was originally a conditional gift, the plaintiff gave it to her unconditionally, because the defendant offered to return the ring after he ended the relationship, but he answered no, and he told the her that she should keep the ring.

Issue:

Was the plaintiff entitled to the return of engagement ring?

Answer:

No.

Conclusion:

Applying the "fault" standard, the plaintiff failed to prove that the defendant was at fault for their failure to marry. Indeed, the plaintiff admitted that he was at fault for the parties ending their relationship and not getting married. Applying the "modern" no-fault approach, the defendant had established that the engagement ring's status was altered by the plaintiff when he later gave her the ring unconditionally after the parties ended their relationship.