Lindh v. Surman

Brief Fact Summary. The Plaintiff sued the Defendant to recover an engagement ring, or its value, after the engagement was broken.

Synopsis of Rule of Law. The donor of an engagement ring (which is a conditional gift) is entitled to the return of the ring even if the donor broke the engagement.

Facts. The Plaintiff Lindh, in 1993, asked the Defendant Surman to marry him, and the Defendant accepted the proposal along with a ring which Plaintiff purchased for $17,400, but that was valued at $21,200. Thereafter, the couple split later that year, and Plaintiff broke the engagement asking for return of the ring. The Defendant at that time returned the ring. Later, the couple attempted to reconcile and decided again to get married. The Plaintiff again gave the ring to Defendant in contemplation of marriage. Then, in 1994, Plaintiff again called off the engagement and asked for the ring back. Defendant refused to return the ring and the Plaintiff filed this lawsuit. The case was presented to arbitration, where the Defendant prevailed. Plaintiff appealed the arbitrator’s decision to a trial court where the non-jury trial resulted in a verdict for Plaintiff in the amount of $21,200. Defendant appealed to the intermediate appellate court which affirmed the decision of the trial court
. Then Defendant appealed to the Supreme Court of Pennsylvania.

Issue. Does the fact that the engagement ended due to the fault of the Plaintiff create a condition that does not require the Defendant to return the ring?

Held. No. The judgment is affirmed.
First, the Court notes that the gift of an engagement ring is a conditional gift. The condition of the gift is that the parties must actually become married for the complete title of the ring to vest in the donee. Mere acceptance of a marriage proposal does not satisfy the requirement.
The Court finds that an analysis of which party was at fault in the break-up of the engagement is not required to determine the rights of the parties. The Court finds that the issues which lead to the ending of engagements are too complex to be successfully and fairly litigated.
The Court therefore adopts a no-fault approach in determining these cases. This approach is favored by the Court because there may be situations which arise which cause a party to end an engagement where the party may be justified. The no-fault rule is favored to provide certainty in this type of case. The donor of an engagement ring is thus entitled to its return even if the donor himself broke the engagement.

Dissent. There are two dissents in this case.
The trial courts should easily be able to apply a fault-based rule in these cases, due to the fact that the trial courts face fact patterns which are sordid every day.
The Restatement of Restitution, Section:58 comment c, discusses this type of case and states that such gifts made in anticipation of marriage are normally not recoverable in absence of fraud.

Discussion. These cases are fairly simple and if one ever encounters such a case, it would be wise to simply check the law of the jurisdiction where the events have occurred before advising a potential clie