West Case Update

Engagement Ring Is Gift in Contemplation of Marriage; Must Be Returned if No Marriage

Description Appeals court held that an engagement ring is a conditional gift that becomes final only if the marriage occurs. If the engagement is broken, regardless of who may be at fault, the condition needed for the gift to be final does not occur, so the ring is the property of the donor.

Topic Contracts

Key Words Marriage; Engagement; Gifts

C A S E S U M M A R Y

Facts Barry Meyer and Robyn Mitnick became engaged on August 9, at which time Barry gave Robyn an engagement ring that cost $19,500. On November 8, Barry asked Robyn to sign a prenuptial agreement, which she refused to do and the engagement was broken. Robyn refused to return the ring. Barry sued. Robyn contended that the ring was an unconditional gift. Barry contended that the ring was a conditional gift given in contemplation of marriage, which did not occur. The trial court held for Barry. Robyn appealed.

Decision Affirmed. A determination of who owns the engagement ring following termination of the engagement does not require a determination of which party was at fault. Marriage is an implied condition of the transfer of title to the ring, so the gift does not become absolute until the marriage occurs. The ring must be returned to its donor.

Citation Meyer v. Mitnick, 244 Mich.App. 697 (2001 WL 171453, Ct. App., Mich., 2001)

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Engagement Ring Is Gift in Contemplation of Marriage; Must Be Returned if No Marriage
Description	Appeals court held that an engagement ring is a conditional gift that becomes final only if the marriage occurs. If the engagement is broken, regardless of who may be at fault, the condition needed for the gift to be final does not occur, so the ring is the property of the donor.
Topic	Contracts
Key Words	Marriage; Engagement; Gifts
C A S E S U M M A R Y
Facts	Barry Meyer and Robyn Mitnick became engaged on August 9, at which time Barry gave Robyn an engagement ring that cost $19,500. On November 8, Barry asked Robyn to sign a prenuptial agreement, which she refused to do and the engagement was broken. Robyn refused to return the ring. Barry sued. Robyn contended that the ring was an unconditional gift. Barry contended that the ring was a conditional gift given in contemplation of marriage, which did not occur. The trial court held for Barry. Robyn appealed.
Decision	Affirmed. A determination of who owns the engagement ring following termination of the engagement does not require a determination of which party was at fault. Marriage is an implied condition of the transfer of title to the ring, so the gift does not become absolute until the marriage occurs. The ring must be returned to its donor.
Citation	Meyer v. Mitnick, 244 Mich.App. 697 (2001 WL 171453, Ct. App., Mich., 2001)