Family Law Keyed to Weisberg

back
Topic /161
Meyer v. Mitnick

Citation. Meyer v. Mitnick, 244 Mich. App. 697, 625 N.W.2d 136, 2001 Mich. App. LEXIS 36 (Mich. Ct. App. Feb. 20, 2001)

Brief Fact Summary. Plaintiff and defendant were engaged to marry and plaintiff gave defendant an engagement ring. The engagement was terminated and plaintiff brought suit against defendant to recover the ring.

Synopsis of Rule of Law. Because engagement rings are conditional gifts given in contemplation of marriage, the ring should be returned to the donor on breaking of the engagement without a determination regarding fault.

Facts. Plaintiff Barry Meyer and defendant Robyn Mitnick became engaged. Plaintiff gave defendant a custom designed engagement ring. Plaintiff asked defendant to sign a prenuptial agreement and defendant refused, causing the engagement to be broken. Both parties claimed the other caused the breakup. Barry brought suit for the engagement ring, claiming it was a conditional gift given in contemplation of marriage. Defendant counterclaimed that the ring was an unconditional gift, and that she was entitled to keep it because plaintiff broke off the engagement. The trial court granted plaintiff’s motion for summary judgment.

Issue. When determining ownership of an engagement ring following termination of an engagement, should fault be considered?

Held. Engagement rings should be considered conditional gifts given in contemplation of marriage.
Previous state precedent cited the general principal that if an engagement is unjustifiable broken by the donor of an engagement ring, he could not recover the ring. The previous court justified this based upon finding of fault in the conduct of one of the parties. The same Court noted that if an engagement is expressly terminated by mutual consent, the donor may obtain recovery.

The older rule is generally that if an engagement is unjustifiably broken by the donor, he cannot recover the ring. The modern trend is that because of the inherently conditional nature of the gift, the ring should be returned to the donor once the engagement is broken. This court finds the modern trend persuasive.

Discussion. The Court finds that a fault determination should not be examined because fault is impossible to fix based on the inherently fickle reasons people choose to not marry.