White v. Finch
3 Conn. Cir. Ct. 138 · Connecticut Appellate Court · 1964
Facts
In October 1962, the plaintiff met the defendant, and they developed a mutual fondness. The plaintiff proposed marriage before Christmas 1962, but the defendant initially demurred. On February 13, 1963, the plaintiff renewed his proposal, which the defendant accepted, and he subsequently gave her an engagement ring. Over the following months, their relationship encountered difficulties, including infrequent meetings, the plaintiff's premature wedding announcements, and a dispute over the defendant entering a beauty contest. The plaintiff, suspecting the worst after not finding the defendant at home, later told her, "As far as I am concerned, this engagement is through," effectively ending the engagement. The defendant returned all other gifts but refused to return the engagement ring, prompting the plaintiff to sue for its value.
Issue
The legal question is whether the plaintiff, as the donor, can recover the engagement ring or its value after he unilaterally terminated the engagement. Specifically, can the donor recover the ring when he broke the engagement?
Holding
The court held that the plaintiff could not recover the engagement ring's value. Judgment was entered for the defendant.
Rule
The prevailing legal view is that an engagement ring is a conditional gift, given upon the implied condition that the marriage will take place. If the engagement is broken due to the donor's fault, the donor may not recover the ring. A breach of a promise to marry requires a distinct, unequivocal, and absolute refusal to perform. The plaintiff's statement, "As far as I am concerned, this engagement is through," constituted such a breach, placing the fault for the termination on him. Therefore, the plaintiff, having initiated the breach, failed to sustain his burden of proof to recover the ring.
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