Cooper v. Smith

Rule of Law:

An engagement ring is a gift conditional on the marriage occurring and must be returned if the engagement is broken, regardless of fault. All other gifts exchanged during an engagement are considered absolute inter vivos gifts and are not recoverable unless they were given with an express condition that they be returned if the marriage failed.

Facts:

• In May 2001, Lester Cooper was hospitalized for a serious injury.
• While hospitalized, he began a romantic relationship with Julie Smith, who was married to another man at the time.
• Cooper proposed to Julie while still in the hospital, and she accepted, indicating she would marry him after she divorced her husband.
• Julie divorced her husband in October 2001, but she and Cooper did not marry.
• Cooper received a $180,000 settlement for his injuries and moved in with Julie and her mother, Janet Smith.
• Cooper used his settlement money to purchase numerous items for Julie, including a diamond engagement ring, a car, and horses.
• Cooper also paid off Janet's car loan and paid for significant improvements to her house, including a new furnace and flooring.
• In June 2002, Cooper had a dispute with Janet and moved out, and the following month Julie ended their relationship after Cooper stated his intent to sue her mother.

Procedural Posture:

• Lester Cooper filed a complaint against Julie Smith and Janet Smith in the Lawrence County Common Pleas Court (a trial court).
• The case proceeded to a trial before a magistrate.
• At the end of Cooper's presentation of evidence, the defendants moved to dismiss his complaint.
• The magistrate granted the motion to dismiss, finding the gifts were not conditional on marriage.
• Cooper filed objections to the magistrate’s decision with the trial court judge.
• The trial court overruled the objections and entered a final judgment dismissing Cooper's complaint.
• Cooper (appellant) appealed the dismissal to this court, the intermediate court of appeals.