Wednesday, September 13, 2023

This Diamond Ring

The Massachusetts Appeals Court reversed and remanded a matter involving a broken engagement

After calling off their wedding and ending the parties' engagement, the plaintiff brought this action in the Superior Court against his former fiancée, seeking the recovery of an engagement ring and two wedding bands that he had purchased. The defendant counterclaimed for breach of contract seeking funds to complete a dental implant surgery that the plaintiff had promised to pay for during their relationship. We reverse the Superior Court judge's disposition awarding the engagement ring and one wedding band to the defendant and vacate the award of prejudgment interest, which is to be recalculated on remand.

The two became a couple shortly after meeting They travelled and made purchases on plaintiffs dime.

The plaintiff paid for these vacations and expected nothing from the defendant in return. He also often bought the defendant expensive gifts, including jewelry, clothing, shoes, handbags, and artwork. It was the plaintiff's custom to provide the defendant with receipts for the gifts.

An old fashioned marriage proposal

In August 2017, the two went to lunch with the defendant's parents. Once the defendant stepped away from the table, the plaintiff asked her father for permission to marry her, to which the father said yes. Later that day, the plaintiff and defendant had dinner at a restaurant where the plaintiff had arranged ahead of time to be seated at a corner-window table. During dinner, the plaintiff asked the defendant to marry him and presented her with the diamond engagement ring. The defendant said yes and placed the ring on her own left ring finger. The ring was given, and accepted, in anticipation of marriage.

The ring is valued at "over $70,000."


As the wedding planning progressed, the plaintiff noticed that he found some traits of the defendant to be troubling. Following their engagement, the plaintiff began to feel that he was routinely subject to verbal abuse. For instance, the defendant would berate the plaintiff over a spilled drink, how he ate oysters, and the time it took him to access messages on his cell phone. She would call him a "moron" and treat him like a child. If something went wrong, he was to blame. If the plaintiff stood up for himself, the defendant would yell at him and storm away. The plaintiff also felt that the defendant did not appreciate any of his accomplishments, and that she did not support him following his cancer diagnosis. Despite these concerns, the plaintiff thought they could fix these issues and make the relationship work

But after a fight over an alleged affair of defendant

The next morning, the plaintiff confronted the defendant about the messages and accused her of having an affair. She denied the accusation and explained that the man was her best friend of over forty years and that their friendship was strictly platonic. A week or two later, the plaintiff called the defendant and ended their engagement by leaving a voicemail message, stating that he felt disrespected and that he could not trust her. This lawsuit followed.

The jury found that there was no affair and deemed plaintiff "at fault"

we conclude that the evidence was insufficient to sustain a finding that the plaintiff was "at fault" for the parties' separation. See Kendall, 413 Mass. at 621 ("the 'clearly erroneous' standard of appellate review does not protect findings of fact or conclusions based on incorrect legal standards"). 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. Sometimes there simply is no fault to be had. See Gaden v. Gaden, 29 N.Y.2d 80, 88 (1971) ("In truth, in most broken engagements there is no real fault").

The plaintiff is entitled to the return of the engagement ring and wedding band.  Judgment shall enter for the plaintiff on this count.

Justice Milkey dissented in part

Were I the fact finder here, I would not have found the plaintiff at fault for terminating the parties' engagement. After all, although his suspicion that his fiancée was having an affair proved incorrect (according to the unreviewable credibility findings made by the judge), the plaintiff had what I consider an objectively reasonable basis for forming such a belief. And, in any event, after the flurry of accusations and heated responses on both sides caused the relationship to unravel, I do not believe that the plaintiff can be blamed for reaching the eminently reasonable conclusion that this marriage was not destined to be. In this respect, my own views are closely aligned with those of the majority.

But I am not the fact finder, and the trial judge found the plaintiff at fault after hearing testimony from all involved. I do not think that finding fairly can be said to be clearly erroneous on this record.

The rule of law

None of this is to say that I think the defendant here should have kept the ring. To the contrary, my own view is that she should have given it back. But why should my personal view on this issue matter? To me, the ultimate question this case poses is whether such issues should be resolved in courts of law, or instead left to the interplay between private conscience and social norms.

(Mike Frisch)

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