Timothy F. Rayne, Esquire

A Pennsylvania Supreme Court decision says that engagement rings are given conditionally, and must be returned in lieu of a marriage event

Today, engagement rings can run from hundreds of dollars to a hundred thousand dollars. So, when an engaged couple fails to make it down the aisle, which party keeps the ring? A landmark Pennsylvania Supreme Court ruling has decreed that an engagement ring is a gift "conditioned" on the marriage event. Hence, if the marriage is cancelled by either party, the ring must be returned to the purchaser.

The Case
The case that set the precedent in Pennsylvania was Lindh v. Surman. In August of 1993, Rodger Lindh, a divorced middle–aged man, proposed to Janis Surman, a younger woman who had never been married. Rodger presented Janis with a diamond engagement ring that he purchased for $17,400. Rodger indicated that the actual value of the ring was $21,200 and that he got a special deal because he was a "good customer," having bought his ex–wife's ring and various pieces of jewelry for his children from the jeweler.

When problems arose between the couple later that year, Rodger broke off the engagement and asked Janis to return the ring. Janis obliged. Later, the two reconciled and Rodger proposed again, giving back to Janis the same ring. For a second time, Janis accepted. In March of 1994, however, Rodger called off the engagement again and demanded the return of the ring. This time Janis refused, and litigation ensued.

Arbitration and Lower Court Rulings
In the litigation, a panel of arbitrators ruled that Janis could keep the ring. A judge of the Court of Common Pleas held otherwise, awarding Rodger a judgment of $21,200. The Pennsylvania Superior Court upheld the Trial Court's decision.

Pennsylvania Supreme Court Ruling
In arguing the case before the Supreme Court, the parties agreed that the engagement ring was a conditional gift. However, they disagreed on two points: (1) what was the condition of the gift (acceptance of the engagement or the marriage itself); and (2) whether fault was relevant to determining the return of the ring. Ultimately, the Supreme Court held for Rodger on both points.

The court found that the gift was conditioned on the actual marriage, not just acceptance of the engagement. The Supreme Court further determined that a fault analysis (a determination of who was responsible for breaking off the engagement) was not appropriate. Pennsylvania, like most states, has adopted a "no fault" system in divorce cases (a divorce can be obtained without proving fault by either party). The Court indicated that such a "no fault" system would be appropriate in an engagement ring case because of the difficulty of determining who was "wrong" or "right" in the breakup of the engagement. To determine who was at "fault" would require a detailed inquiry into the facts surrounding the demise of the relationship.

Rather than burdening the lower courts with such unpleasant disputes, the Supreme Court adopted a "no fault" system in which the husband–to–be is entitled to return of the ring even if he breaks off the engagement. Therefore, in this case, Janis was forced to either return the ring or pay Rodger $21,200.

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