Campbell v. Robinson

398 S.C. 12 · Court of Appeals of South Carolina · 2012

Facts

Matthew Campbell proposed to Ashley Robinson in December 2005 and gave her an engagement ring. In spring 2006, they agreed to postpone the wedding, and the engagement was later cancelled. A dispute arose over the ownership of the ring, with Campbell seeking its return and Robinson claiming he told her to keep it. Campbell filed suit to reclaim the ring and for restitution, while Robinson counterclaimed for breach of promise to marry.

Procedural history

Campbell moved for directed verdict on Robinson's breach of promise to marry claim and his own claims, and Robinson also moved for directed verdict. The trial court denied these motions, ruling that South Carolina recognizes breach of promise to marry and that ring ownership depended on who was "at fault." The jury found Campbell responsible for the termination but awarded Robinson no damages. Both parties' post-trial motions for JNOV or new trial were denied, leading to this appeal.

Issue

Did the trial court err by denying Campbell's motions regarding engagement ring ownership based on a "fault" standard? Is the "fault" of a party in ending an engagement relevant to determining ownership of an engagement ring?

Holding

The court affirmed that South Carolina still recognizes breach of promise to marry actions and that Campbell was not entitled to restitution. However, the court reversed the trial court's decision regarding engagement ring ownership, holding that fault is not a factor. The case was remanded for a new trial on Campbell's claims for declaratory judgment and claim and delivery due to an erroneous jury charge.

Rule

An engagement ring is a conditional gift, impliedly conditioned upon the marriage taking place. If the marriage does not occur, the ring must be returned to the donor upon request, unless it was converted into an absolute gift. The court explicitly holds that the "fault" of either party in ending the engagement has no place in determining ownership of an engagement ring, as there is no legal standard to adjudge culpability in a prenuptial breakup. The person challenging the conditional nature of the gift can present evidence that the ring was not given in contemplation of marriage, was not conditioned on marriage, or subsequently became an absolute gift (e.g., donor told donee to keep it).

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Case brief last reviewed 2026-10-01. Prepared by CaseReader from the published opinion.