Curtis v. Anderson
106 S.W.3d 251, 2003 WL 1832257 (2003)
Rule of Law:
Absent a written agreement between engaged parties, an oral agreement for the return of an engagement ring is unenforceable under the Statute of Frauds, and the fault-based conditional-gift rule dictates that a donor is not entitled to the return of an engagement ring if the donor is responsible for terminating the engagement.
Facts:
- In the summer of 2000, Michael Curtis and Michele Anderson became engaged to be married.
- Michael Curtis gave Michele Anderson a diamond ring.
- Curtis alleged that at the time he gave the ring, Anderson verbally agreed that she would return it if the wedding was called off, stating they had a "mutual understanding."
- Approximately six or eight weeks after the engagement, Curtis terminated the engagement.
- Curtis ended the engagement for various personal reasons, including his perception of Anderson's "sexual hang-ups," "previous general issues with men," and "volatile temper."
- Anderson refused to return the ring to Curtis after the engagement ended.
Procedural Posture:
- Michael Curtis sued Michele Anderson in the trial court for breach of an oral agreement and conversion.
- Michele Anderson moved for summary judgment, asserting that Curtis's claims were barred by the Statute of Frauds.
- The trial court granted Michele Anderson's motion for summary judgment.
- Michael Curtis appealed the trial court's summary judgment to the Court of Appeals of Texas, Austin (Michael Curtis is the appellant, Michele Anderson is the appellee).
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Issue:
Does the Texas Family Code's Statute of Frauds (Section 1.108) render an oral agreement for the return of an engagement ring unenforceable, and if not, does the conditional-gift rule, when the donor breaks the engagement, entitle the donor to the ring's return or establish a claim for conversion?
Opinions:
Majority - Lee Yeakel, Justice
No, an oral agreement for the return of an engagement ring is unenforceable under the Statute of Frauds, and a donor who terminates the engagement is not entitled to the return of the ring under the conditional-gift rule, thus failing to establish a claim for conversion. The court first addressed the enforceability of Curtis's alleged oral agreement. It held that Section 1.108 of the Texas Family Code, the Statute of Frauds, applies to agreements made "on consideration of marriage," which includes promises regarding engagement gifts. Since engagement rings are traditionally given in contemplation of marriage, any agreement for their disposition if the marriage does not occur must be in writing to be enforceable. Curtis's testimony about a "mutual understanding" was not in writing, rendering it unenforceable. Next, the court considered the conditional-gift rule in the absence of an enforceable agreement. Texas courts have historically applied a fault-based conditional-gift rule, requiring the ring's return to the donor if the donee is at fault for terminating the engagement, citing precedents like McLain v. Gilliam. This case presented the opposite scenario: the donor, Curtis, admittedly terminated the engagement and did not claim Anderson was at fault. The court, looking to other jurisdictions and seeking to apply the rule symmetrically, concluded that if the donor terminates the engagement, the donor is not entitled to the return of the ring. To hold otherwise would penalize the donee for the donor's breach of the promise to marry. Finally, the court dismissed Curtis's conversion claim. A claim for conversion requires the plaintiff to establish ownership or a superior right to immediate possession of the property. Because Curtis could not establish such a right under either the unenforceable oral agreement or the conditional-gift rule, his conversion claim failed as a matter of law.
Analysis:
This case significantly clarifies Texas law regarding engagement rings by applying the Statute of Frauds to oral agreements concerning their disposition, mandating a written agreement for enforceability. Furthermore, it extends and symmetrically applies the fault-based conditional-gift rule, establishing that a donor who initiates the breakup is not entitled to the ring's return. This ruling provides crucial guidance for engaged couples and resolves ambiguity in situations where the donor, not the donee, terminates the engagement, thereby promoting the use of clear, written agreements for premarital gifts.
