Who's at fault when engagement ends? Appeals court considers issue in suit for return of $70K ring
“Common sense dictates that a party who ends an engagement is not necessarily the one to blame for that result,” the Massachusetts Appeals Court said. “Were it otherwise, fault in the engagement termination context would be more akin to strict liability.” Image from Shutterstock.
A man who called off his engagement is entitled to the return of a $70,000-plus engagement ring and a wedding band, the Massachusetts Appeals Court has ruled in a 2-1 decision.
The appeals court ruled Sept. 13 for Bruce Johnson in his lawsuit against former fiancee Caroline Settino. The Legal Profession Blog noted the decision.
Massachusetts law allows the return of an engagement ring if a contract to marry is terminated without fault on the part the person seeking its return. At issue in the case is how to assess fault, the appeals court said.
Johnson said during the engagement, he began to find some of his fiancee’s traits troubling. According to Johnson, Settino berated him “over a spilled drink, how he ate oysters, and the time it took him to access messages on his cellphone. She would call him a ‘moron’ and treat him like a child. If something went wrong, he was to blame.”
After an argument, Johnson looked at Settino’s text messages and found a text to a man Johnson didn’t know. It read, “My Bruce is going to be in Connecticut for three days. I need some playtime.” He also listened to a voicemail message by the same man who was upset because Settino did not see him often enough.
Johnson interpreted the message as an invitation for sex and accused Settino of having an affair. Settino said the person she texted had been a friend for more than 40 years, and the relationship was strictly platonic. A week or two later, Johnson ended the engagement.
Settino had counterclaimed for breach of contract, alleging that Johnson had promised to pay for dental implant surgery. Settino’s upper teeth were extracted for the first part of the procedure in 2017, and she wanted funds to complete the process.
A judge had allowed Settino to keep the engagement ring and one of two wedding bands and had entered judgment for Settino on the dental work counterclaim along with prejudgment interest. The wedding band award was not challenged on appeal. But Johnson wanted the engagement ring and the other wedding ring back, and he objected to the award of prejudgment interest.
The Massachusetts Appeals Court considered how fault is handled by other state courts. A minority of states use a fault-based approach in determining which party owns the ring. Some cases assess fault based on which party broke off the engagement, while others consider which party’s conduct caused the breakup to occur.
The majority rule is the “modern no-fault approach.” It holds that the ring is a conditional gift that must be returned when an engagement is terminated, regardless of fault.
At least one court, on the other hand, has adopted a no-fault rule that treats the ring as an irrevocable gift.
The Massachusetts Appeals Court said it can’t adopt a no-fault approach because it is an intermediate appeals court without that authority. In assessing fault, the appeals court rejected an approach that attributes fault to the person who ended the relationship.
“Common sense dictates that a party who ends an engagement is not necessarily the one to blame for that result,” the Massachusetts Appeals Court said. “Were it otherwise, fault in the engagement termination context would be more akin to strict liability.”
The appeals court pointed to a trial judge’s findings that Settino was not having a sexual affair. Johnson had argued, however, that he had justifiably lost faith in Settino, even if there was no affair. The appeals court agreed with Johnson.
“Although the plaintiff may have largely been motivated by a mistaken belief, we cannot say that he was unjustified or did not have adequate cause to break the engagement under the circumstances presented,” the Massachusetts Appeals Court said. “Sometimes there simply is no fault to be had.”
The appeals court upheld the award of prejudgment interest but said it was improperly calculated.
A dissenter said the trial judge’s determination that Johnson was at fault was not clearly erroneous and should be upheld. The majority had effectively moved to a no-fault standard while acknowledging that the appeals court lacked authority to do so, the dissent said.
Settino represented herself in oral arguments (beginning at 1:45:30 of this video).
