Property I, Pages 213–217

Lindh v. Surman

Supreme Court of Pennsylvania, 1999

Facts:

Plaintiff proposed to defendant with a ring purchased for $17,400. Plaintiff testified that it was worth more, but received a discount for being a repeat customer, having purchased an engagement ring for his ex-wife and various pieces of jewelery for his children there. Defendant accepted plaintiff's proposal. Two months later plaintiff called off the engagement and asked for $17,400 ring back. Defendant obliged and gave plaintiff the ring back. They then reconciled however, and plaintiff proposed again. Defendant again accepted. Plaintiff then again called off the engagement in a couple of months and asked for the ring back. This time defendant refused.

Procedural History:

Arbitrators awarded judgment for defendant. Plaintiff appealed to the Court of Common Pleas of Allegheny County, where a brief non-jury trial resulted in a judgment for plaintiff for $21,200. Defendant appealed to the Superior Court, which affirmed the trial court, holding that the ring must be returned regardless of who broke the engagement and their reasons for doing so.

Issues:

  • What is the condition of the gift of the engagement ring?

  • Is fault relevant to determining return of the engagement ring?

Defendant's Argument:

The condition of the gift is acceptance of the proposal of marriage. If the donor breaks off the engagement, his right of recovery should not be recognized because he is the one who prevented the condition's fulfillment.

Rule:

Pennsylvania law treats the giving of an engagement ring as a gift conditional on marriage.

Reasoning:

Caselaw doesn't say who gets the ring when an engagement is broken off. Either a fault-based or a no-fault position could be taken. However, a fault-based system would be way too complex and bring out the worst accusations as to fault by both parties.

Holding:

Page 216, Paragraph 5

[T]he donor is entitled to return of the ring even if the donor broke the engagement.

Judgment:

Affirmed.

Dissenting Opinion:

Cappy: Ease of avoiding figuring out who was at fault could be adopted in any case. Courts must determine fault in abuse and criminal cases, so they should in these cases too. To do otherwise would add insult to injury of the poor fiancée.

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