Johnson v. Settino
22-P-941 Appeals Court (2023)
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Rule of Law:
In a dispute over an engagement ring after a terminated engagement, the donor may recover the ring if they ended the relationship 'without fault.' Being 'without fault' requires a justification analysis, meaning the donor must have had adequate cause to terminate the engagement, even if their belief leading to the termination was factually mistaken.
Facts:
- Bruce Johnson and Caroline Settino began dating in the summer of 2016.
- During their relationship, Johnson was financially generous, paying for vacations and promising to pay for Settino's dental implant surgery, for which he funded the initial tooth extraction phase.
- In August 2017, Johnson proposed to Settino with a diamond ring valued at over $70,000, which she accepted. The ring was given in anticipation of marriage.
- In October 2017, Johnson purchased two wedding bands and gave them to Settino, also in anticipation of marriage.
- Johnson grew concerned with Settino's behavior, feeling she was verbally abusive and unsupportive.
- In November 2017, Johnson discovered a text message on Settino's phone to another man that read, 'My Bruce is going to be in Connecticut for three days. I need some playtime,' along with a related voicemail.
- Interpreting these messages as evidence of infidelity, Johnson confronted Settino, who denied the accusation and claimed the man was a platonic friend.
- A week or two later, Johnson terminated the engagement via voicemail, stating he felt disrespected and could no longer trust her.
Procedural Posture:
- Bruce Johnson filed a civil action against Caroline Settino in the Superior Court Department to recover the engagement ring and wedding bands.
- Settino filed a counterclaim for breach of contract to recover costs for a dental procedure Johnson had promised to pay for.
- Following a jury-waived trial, the Superior Court judge found that Johnson was at fault for the breakup because his belief about an affair was mistaken.
- The trial court awarded the engagement ring and one wedding band to Settino and entered judgment for Settino on her counterclaim, including damages and prejudgment interest.
- Johnson (appellant) appealed the trial court's judgment to the Appeals Court, challenging the finding of fault regarding the rings and the calculation of prejudgment interest. Settino is the appellee.
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Issue:
Does a donor of an engagement ring act 'with fault,' thereby forfeiting the right to recover the ring upon a broken engagement, when he terminates the relationship based on a mistaken, but not unreasonable, belief that the donee was unfaithful?
Opinions:
Majority - Singh, J.
No. A donor who terminates an engagement based on a mistaken belief does not act 'with fault' if the termination was justified or based on adequate cause. Assessing fault requires a justification analysis, not merely identifying who initiated the breakup. The trial judge erred by focusing on whether Settino was actually having an affair, rather than on whether Johnson was justified in ending the engagement based on the circumstances. The court found that Johnson's discovery of the text message and voicemail gave him adequate cause to lose trust and terminate the relationship, even if his belief about an affair was mistaken. Therefore, he was 'without fault' under the standard set by De Cicco and is entitled to the return of the engagement ring and the wedding band. The court also held that wedding bands given in anticipation of marriage are treated as conditional gifts, the same as an engagement ring.
Dissenting - Milkey, J.
Yes. A donor can be found to be 'at fault' when he ends an engagement based on a mistaken belief. The trial judge's determination that Johnson was at fault is a finding of fact that was not clearly erroneous and should be affirmed. The trial judge was entitled to find fault with someone who wrongly accused his fiancée of infidelity after searching her phone without permission. While the dissenter personally might have reached a different conclusion, it is not the role of an appellate court to re-weigh the evidence and substitute its own judgment for that of the fact-finder. The dissent further suggests that the Supreme Judicial Court should reconsider the entire fault-based, conditional-gift framework for engagement rings, as it is unseemly for courts to adjudicate 'matters of the heart.'
Analysis:
This decision significantly refines the 'fault' standard for recovering engagement rings in Massachusetts. It moves the analysis away from a simple determination of who ended the engagement or proving wrongful conduct, and toward a justification or 'adequate cause' standard. This makes it easier for a donor to recover a ring by showing their reason for ending the engagement was reasonable under the circumstances, even if based on a factual mistake. The ruling discourages courts from conducting invasive inquiries into the romantic lives of litigants and instead focuses on the justification for the decision to terminate the relationship, potentially aligning the common law more closely with the state's no-fault approach to divorce.
