Clippard v. Pfefferkorn
2005 WL 1263071, 2005 Mo. App. LEXIS 809, 168 S.W.3d 616 (2005)
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Rule of Law:
Under Missouri's fault-based approach, the donor of an engagement ring, which is a gift conditional upon marriage, is not entitled to its return if the donor terminates the engagement without fault on the part of the donee.
Facts:
- Chad Clippard and Jamie Pfefferkorn dated for approximately four to five months in late 2002.
- On or about December 23, 2002, Clippard proposed marriage to Pfefferkorn and presented her with a diamond engagement ring valued at approximately $13,500.
- Pfefferkorn accepted both the marriage proposal and the ring.
- The couple experienced difficulties in their relationship over the following weeks.
- On or about February 8, 2003, Clippard terminated the engagement.
- Clippard attributed his decision to a belief that Pfefferkorn was not the 'right' person for him and to the influence of his family.
- Clippard demanded the ring's return, and Pfefferkorn refused.
Procedural Posture:
- Chad Clippard (Plaintiff) filed a petition in a Missouri trial court against Jamie Pfefferkorn (Defendant) for the return of an engagement ring or its monetary value.
- Following a bench trial, the trial court entered a judgment in favor of Defendant Pfefferkorn.
- Plaintiff Clippard appealed the trial court's judgment to the Missouri Court of Appeals, Eastern District.
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Issue:
Does the donor of an engagement ring have a right to its return when the donor unilaterally terminates the engagement for reasons not attributable to the fault of the donee?
Opinions:
Majority - Hoff, J.
No. The donor of an engagement ring is not entitled to its return when the donor terminates the engagement without fault on the part of the donee. The court determined that an engagement ring is not an absolute gift but a conditional gift given in contemplation of marriage. Missouri law applies a fault-based approach to determine entitlement to such gifts when the engagement is broken. Precedent establishes that a donor can recover the gift if the donee breaches the engagement without the donor's fault. The court reasoned that the logical inverse is also true: the donee is entitled to retain the conditional gift if the donor terminates the engagement for reasons not constituting fault by the donee. In this case, Clippard terminated the engagement because he felt Pfefferkorn was not the 'right' person and due to family pressure, which does not constitute fault on Pfefferkorn's part. Therefore, by breaching his promise to marry, Clippard forfeited his right to recover the ring.
Analysis:
This decision solidifies Missouri's adherence to a traditional, fault-based approach for resolving disputes over engagement rings, which contrasts with the modern, no-fault trend adopted in many other jurisdictions. By applying the inverse of established precedent, the court clarifies that the party who breaks the engagement without justification forfeits their right to the ring, regardless of whether they are the donor or the donee. This ruling reinforces the idea that an engagement is a promise, and the breach of that promise has tangible consequences concerning conditional gifts made in reliance on it.
