Campbell v. Robinson
726 S.E.2d 221, 2012 WL 1618670, 398 S.C. 12 (2012)
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Rule of Law:
Ownership of an engagement ring after a broken engagement is determined by the law of conditional gifts, not by which party was at fault for the breakup. The ring is a gift conditioned upon the marriage occurring and must be returned to the donor if the marriage does not take place, unless the donor subsequently manifests an intent to make the gift absolute.
Facts:
- In December 2005, Matthew Campbell proposed to Ashley Robinson and gave her an engagement ring.
- In the spring of 2006, Campbell and Robinson mutually agreed via a phone conversation to postpone their wedding.
- The engagement was later cancelled.
- Following the cancellation, Robinson testified that Campbell twice told her she should keep the ring.
- Campbell testified that the cancellation was mutual, denied telling Robinson she could keep the ring, and contended she refused to return it upon his request.
Procedural Posture:
- Matthew Campbell filed suit against Ashley Robinson in a South Carolina trial court seeking return of the engagement ring or its value.
- Robinson filed a counterclaim for breach of promise to marry.
- At trial, both parties moved for a directed verdict.
- The trial court denied the motions and ruled that ownership of the ring would be determined based on which party was 'at fault' for the engagement's termination.
- The jury found that Campbell was responsible for the termination of the engagement but awarded no damages to Robinson.
- Campbell moved for judgment notwithstanding the verdict (JNOV) or a new trial, which the trial court denied.
- Robinson moved for JNOV and a new trial on damages, which the trial court also denied.
- Campbell appealed the trial court's rulings to the Court of Appeals of South Carolina.
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Issue:
Does a trial court commit a legal error by instructing a jury to determine ownership of an engagement ring based on which party was 'at fault' for the termination of the engagement?
Opinions:
Majority - Thomas, J.
Yes. Determining ownership of an engagement ring based on which party was at fault is a legal error. An engagement ring is an impliedly conditional gift, given in contemplation of marriage. The gift is not complete until the condition—the marriage—is fulfilled. If the engagement is broken and the marriage does not occur, the gift is unenforceable and must be returned to the donor upon request. The court explicitly adopts this 'no-fault' approach, reasoning that there is no objective legal standard for determining fault in a breakup and that a fault-based inquiry could penalize a party for wisely ending an incompatible relationship. However, a conditional gift can be converted into an absolute gift if the donor, after the breakup, manifests a clear intent for the donee to keep the property. Because Robinson presented evidence that Campbell told her to keep the ring, a disputed issue of fact exists for a jury to decide, making a new trial with proper instructions necessary.
Analysis:
This decision officially aligns South Carolina with the modern, majority 'no-fault' approach to resolving disputes over engagement rings. It definitively rejects the older, fault-based inquiry, thereby simplifying litigation by removing the need for courts to delve into the personal details of a breakup to assign blame. The ruling establishes a clear precedent that such cases are to be analyzed strictly under the principles of conditional gift law. Future disputes will now center on whether a ring was given in contemplation of marriage and whether any subsequent actions or statements by the donor converted the conditional gift into an absolute one.
