Yes. The court decided that an engagement ring is a gift that depends on a wedding actually happening. If there's no wedding, the ring goes back. The judges didn't want to get into a messy he-said-she-said about who was to blame for the breakup. They created a simple 'no-fault' rule, like in modern divorce, so the answer is the same every time: the giver gets the ring back.

No. This judge disagreed, saying the person who breaks the promise to get married shouldn't be rewarded by getting the ring back. He argued that courts are perfectly capable of figuring out who was at fault and that the 'no-fault' rule is unfair to the person who was ready to get married but got dumped.

No. This judge also disagreed, saying it's not fair to the innocent person. He believed that since Janis didn't do anything wrong to cause the breakup, she should get to keep the ring. He thought the court should look at who was at fault.

Yes, Janis has to give the ring back to Rodger, even though he was the one who called off the wedding. The court says it doesn't matter who ended the engagement or why. If the couple doesn't get married, the ring goes back to the person who gave it. The court believes this rule is simpler and avoids the need for judges to look into the personal reasons why an engagement ended, which could get very unpleasant.

No, the court should stick with the old rule that says the person who receives the ring can keep it if the other person is the one who calls off the wedding for no good reason. It's not fair to make a bride give back her ring after she and her family may have spent a lot of money getting ready for the wedding, especially if she didn't do anything wrong. Judges deal with difficult personal situations all the time, so it's not a good excuse to say we need this new rule to make their job easier.

No, the court shouldn't use a rule that ignores who is at fault when deciding who gets to keep the ring. In this case, Rodger broke his promise to marry Janis twice and she didn't do anything wrong. It's only fair that Janis gets to keep the ring that was given to her as an unconditional gift. The lower court's decision should be reversed.

—the Supreme Court of Pennsylvania held that in circumstances where a wedding ring had been offered by a man who subsequently broke the engagement (he was, in fact, doing this for the second time), the ring must be returned.

When engagement rings are involved, however, some courts have been willing to imply a condition that the donee must return the ring if the parties do not marry.

It is well established that an engagement ring is a gift impliedly conditioned upon the occurrence of a marriage.

—the court considered but rejected the fault rule followed in some jurisdictions: A ring-return rule based on fault principles will inevitably invite acrimony and encourage parties to portray their ex-fiancees in the worst possible light, hoping to drag out the most favorable arguments to justify, or to attack, the termination of an engagement.

—to 3, adopting a no-fault approach, holding that the ring must be returned to the donor regardless of who broke the engagement, in an opinion by “Madame Justice Newman,” dissent by “Mr. Justice Cappy in which Messrs. Justice Castillo and Saylor join” [Law French resurrected

—court rea-soned that a no-fault approach "involves no investigation into the motives or reasons for the cessation of the engagement and requires the return of the engagement ring simply upon the nonoccurrence of the marriage

—court finds that donor of engagement ring is entitled to its return if marriage does not actually occur, regardless of which party broke the engagement

In such instances there arises an implied condition that title vests in the donee only if and when marriage occurs.[1] Mere acceptance of a proposal of marriage does not suffice to vest title in the donee.

Additionally, in affirming this court's decision in Lindh, our supreme court adopted a no-fault approach to gifts given in contemplation of marriage which requires such a gift to be returned to the donor regardless of who was at fault for ending the relationship.

Yes. The donor of an engagement ring is entitled to its return even if the donor was the one who broke the engagement. An engagement ring is a gift conditioned on the marriage occurring, not on the acceptance of the proposal. Adopting a no-fault rule for the return of engagement rings is consistent with the modern trend in family law, particularly no-fault divorce statutes, and avoids the difficult and acrimonious process of a court determining which party was at fault for a breakup. A clear, no-fault rule provides certainty and is preferable to a fault-based system that would require courts to make subjective judgments about complex personal relationships and would defy universal application.

No. The established principles of conditional gift law should be followed, which would require the party who prevented the marriage from occurring to forfeit the ring. Courts are capable of handling the task of determining fault in broken engagements, just as they do in many other emotionally charged and fact-intensive cases. The majority's no-fault rule creates inequitable outcomes, such as allowing a donor to leave a prospective bride at the altar and then demand the return of the ring, adding insult to injury.

No. A fault-based approach, as suggested by the Restatement of Restitution, should apply. This approach would allow for an equitable outcome where the donee, if not at fault for the termination of the engagement, can retain the ring. Since Janis Surman was the innocent party and Rodger Lindh broke the engagement twice without any allegation of fraud on her part, fairness dictates that she should be allowed to keep the ring.

Yes, the donee must return the ring or its equivalent value to the donor, even if the donor broke the engagement. The court adopts a no-fault approach, requiring the return of the engagement ring upon the nonoccurrence of the marriage, regardless of who broke the engagement or why. This approach avoids the need for courts to investigate the motives or reasons for the engagement's termination, which would invite acrimony and unpleasant accusations between the parties. A thorough fault-based inquiry would not only end with the question of who terminated the engagement, but would also examine that person's reasons, for which there is no clear guidance. The benefits of the certainty of a strict no-fault rule outweigh its negatives and it is less flawed than a fault-based theory or modified no-fault position.

No, the established precedent of conditional gift law in Pennsylvania should be followed, not the modern no-fault trend advocated by the majority. When the marriage does not take place, the agreement is void and the party who prevented the marriage from being fulfilled must forfeit the engagement ring. The majority's concern about relieving trial courts from the task of determining fault in broken engagements is not compelling, as courts regularly deal with equally or more disturbing subject matter. Stripping a faultless bride of her engagement ring after she and her family may have spent thousands in wedding preparations is adding insult to injury.

No, a no-fault policy should not be applied to the issue of which party retains the engagement ring when the engagement is broken. The Restatement of Restitution approach is superior because it allows equity its proper place. Here, the appellee twice broke his engagement with the appellant through no fault of hers and without any allegation that she fraudulently induced the proposals. Fairness dictates that the appellant, as the innocent party, should retain the unconditionally gifted engagement ring. The order of the Superior Court should be reversed.

Lindh v. Surman

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