Massachusetts Court Rules Engagement Rings must be Returned if the Engagement is Terminated, Regardless of Fault
On November 8, 2024, the Massachusetts Supreme Court ruled in the case of Caroline Settino (Caroline) and Bruce Johnson (Bruce) that engagement rings must be returned to the person who provided them if the anticipated wedding does not come to pass, and the engagement is ended. Previously, courts considered which party was “at fault” for ending the engagement when deciding who should keep the ring.
The Lower Court’s Decision on the Engagement Rings
Caroline and Bruce were engaged to be married. When Bruce suspected Caroline of infidelity and ultimately realized he did not wish to marry her, he called off the engagement and filed a lawsuit against Caroline to recover the engagement ring (and the wedding ring) he had already purchased and given to her.
The lower court found that Bruce’s belief that Caroline was being unfaithful to him was unjustified. In its decision, the court cited a holding dating back over 60 years which stated that courts are required to ascertain who is at fault for terminating an engagement in order to find who should possess the engagement/wedding rings. The court used this rule to determine that Bruce was responsible for ending the engagement and must bear the “fault” for the break-up of the relationship. Ultimately deciding that Caroline could keep the rings.
Overturning the “At Fault” Determination
Bruce appealed the lower court’s decision. The Appeals Court held that the party who ends an engagement is not automatically at fault; the actions leading to the decision should be assessed for reasonableness and justification. If one party realizes during the engagement that continuing the relationship would result in an unhappy marriage, ending it may be a prudent decision.
The Supreme Judicial Court adopted the “No-Fault” approach to determining ownership of an engagement ring after the engagement is terminated. The Court continued to hold that engagement rings are a conditional gift. Therefore, if the marriage does not occur and the engagement is ended, the ring must be returned to the person who gives it. The ruling favored Bruce, and Caroline was ordered to return the rings.
Irretrievable Breakdown as Grounds for Divorce
The Supreme Judicial Court’s decision highlights that the concept of fault has become largely irrelevant in modern divorce proceedings. Most divorces in Massachusetts now adopt a no-fault approach, citing “irretrievable breakdown of the marriage” as grounds for divorce. This approach allows married parties to make personal decisions about their relationships without the risk of potentially making embarrassing information public or experiencing undue emotional distress.
Protecting one’s assets and rights when participating in family law matters is essential. A knowledgeable and compassionate attorney can provide the necessary support and advocacy during these challenging situations. If you are interested in scheduling a consultation, you may reach us at 978-637-2048.
