No Wedding, No Ring

Massachusetts Highest Court Overturns 60-Year Precedent Ordering the Return of the Ring After Stalled Engagement

In a recent decision, the Massachusetts Supreme Judicial Court (SJC) created new legal precedent surrounding the return of engagement rings when the engagement ends and the planned wedding does not ensue. The court’s ruling in Johnson v. Settino, case number SJC-13555, abolishes a six-decade-old fault-based analysis, paving the way for a more contemporary standard for ownership in such cases.

In 1938, Massachusetts took its stance on the extent to which courts would resolve disputes arising from private relationships. Massachusetts enacted the “Heart Balm Act”, which prohibited plaintiffs from seeking compensation for emotional damages stemming from the end of a romantic relationship. Specifically, breaches of contracts to marry will not be causes of action recognized by courts in the Commonwealth. M.G.L. c. 207, §47A.

In 1959, the case of De Cicco v. Barker, 339 Mass. 457 (1959), marked a significant moment in this legal landscape. De Cicco held that engagement rings were in essence, “pledges given on the implied condition that the marriage take place.” Meaning that the Massachusetts Heart Balm Act would not preclude actions for the recovery of an engagement ring. The decision was rooted in principles of equity, aiming to prevent the person who received the ring from becoming unjustly enriched when the engagement fails. De Cicco created a fault-based analysis, allowing the donor to reclaim the ring only if the engagement ended without any fault of their own.

Over the years, jurisdictions across the country have shifted away from the fault-based approach. Until recently, Massachusetts had not revisited this standard—until the SJC took up Johnson v. Settino.

The facts of Johnson v. Settino embody the tumultuousness of modern relationships. In the summer of 2016, Johnson began dating Settino. Over the course of their relationship, he “showered [her] with lavish gifts of jewelry, clothing, shoes, and handbags.” A year later, Johnson proposed to Settino with a $70,000 diamond engagement ring.

In November 2017, Johnson discovered text messages on Settino’s phone indicating an intimate relationship with another man. Following this discovery, he terminated the engagement. Johnson subsequently sought the return of the diamond engagement ring and wedding bands.

At trial, the judge ruled that Johnson had given the rings on the condition of marriage but held him at fault for the breakup due to his unfounded suspicions of infidelity. Settino was awarded the engagement ring and wedding band. After an appeal to the Massachusetts Appeals Court, the trial court’s judgment was reversed after holding that ending an engagement does not inherently assign blame to that party. The Appeals Court concluded that Johnson’s actions were reasonable, and the case was ultimately heard by the Massachusetts SJC.

The SJC’s ruling in Johnson v. Settino overturned the fault-based standard that stood firm for the better half of a century. Although the standard was equitable in theory, time has shown the standard to be less practicable. Engagements often fail without clear fault by either party. An engagement period can be, and perhaps should be, viewed as a time to test the permanency of a relationship prior to marriage. A “failed engagement” that prevented in what all likelihood would have been a failed marriage is not a situation where a court should be required to impute blame to one party.  The court argued that assigning fault in such circumstances contradicts the equitable principles the analysis was meant to promote.

Additionally, the SJC pointed out that the fault-based standard is largely irrelevant in Massachusetts divorce proceedings. Likewise, the justices determined fault should not be a relevant consideration in the termination of engagements.

The court ultimately ruled in favor of Johnson, the plaintiff, marking a notable shift in Massachusetts law. Engagement rings are gifts contingent on marriage. When the marriage does not occur, the ring is to be returned to the donor, irrespective of fault.

Alexandre P. Pereira is an Attorney with the law firm of Bacon Wilson, P.C.  He is a member of the Hampden County Bar Association, and the Estate Planning Council of Hampden County. He concentrates his practice in the areas of Elder Law, Estate Planning, Long-Term Care Planning, Probate, and Special Needs Estate Planning. Alexandre may be reached at (413) 781-0560 or [email protected].