Glass v. Wiltz
1989 WL 112120, 551 So.2d 32 (1989)
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Rule of Law:
To recover damages for a breach of promise to marry, a plaintiff must provide clear evidentiary proof causally linking actual damages, such as physical or emotional injuries, directly to the breach of the promise itself, rather than to the general emotional distress resulting from the end of a romantic relationship.
Facts:
- Lawrence D. Glass and Ann P. Wiltz were engaged to be married.
- Glass gave Wiltz a diamond engagement ring valued at $29,000.
- Months before the relationship formally ended, Glass informed Wiltz that he had changed his mind about marrying her.
- Wiltz continued to wear the engagement ring despite believing their engagement was merely a 'charade'.
- Glass ultimately broke off the engagement and terminated the relationship.
- After the final breakup, Wiltz claimed she suffered from embarrassment, humiliation, mental anguish, and physical problems, including a 'cerebral assault,' weight loss, and insomnia.
- Glass requested the return of the engagement ring, but Wiltz refused.
Procedural Posture:
- Lawrence D. Glass sued Ann P. Wiltz in a Louisiana trial court, seeking the return of an engagement ring.
- Wiltz filed a reconventional demand (a counterclaim) against Glass for damages arising from his breach of the promise to marry.
- The trial court ordered Wiltz to return the ring and dismissed her reconventional demand, finding that she failed to prove she had suffered any damages.
- Wiltz, as appellant, appealed the trial court's dismissal of her reconventional demand to the Court of Appeals of Louisiana, Fourth Circuit. Glass is the appellee.
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Issue:
Does a party who breaches a promise to marry owe damages for emotional and physical suffering when the other party fails to provide sufficient evidence, such as expert medical testimony, to prove that the suffering was a direct result of the broken promise rather than the disintegration of the romantic relationship?
Opinions:
Majority - Armstrong, Judge
No. A party who breaches a promise to marry does not owe damages where the claimant fails to prove a direct causal link between the alleged injuries and the breach. Although Louisiana law recognizes a cause of action for breach of promise to marry, the claimant must clearly demonstrate that he or she is free from fault and has suffered actual, proven damages. Here, Ms. Wiltz offered no expert medical testimony to connect her physical ailments to the broken promise. Crucially, her own testimony revealed that she knew months before the final breakup that Mr. Glass no longer intended to marry her. Therefore, the court concluded her ailments were not linked to the legal breach of promise but rather to her 'emotional disappointment following the disintegration of their romance,' for which there is no legal recovery.
Analysis:
This case illustrates the modern judicial skepticism toward claims for breach of promise to marry, significantly raising the evidentiary bar for plaintiffs. By distinguishing between damages stemming from a broken legal promise and the emotional pain from a failed romance, the court narrows the scope of this historic cause of action. The decision establishes that plaintiffs cannot rely on mere allegations of emotional distress or uncorroborated physical symptoms. Instead, they must present concrete evidence, like expert testimony, to establish a direct causal link, making it much more difficult to successfully recover damages in such cases.
