## Facts

- Matthew Campbell proposed to Ashley Robinson in December 2005 and gave her an engagement ring.
- In spring 2006, the parties agreed by phone to postpone the wedding; the engagement was later cancelled.
- The parties disputed who ended the engagement and whether Campbell told Robinson she could keep the ring.
- Campbell sued for (1) declaratory judgment that he owned the ring, (2) claim and delivery with damages for wrongful retention, and (3) restitution based on Robinson’s possession of the ring.
- Robinson counterclaimed for breach of promise to marry, seeking damages for prenuptial expenditures and personal harms.
- The trial court ruled that breach-of-promise actions had not been abolished in South Carolina and instructed the jury to determine ring ownership based on which party was “at fault” for the breakup.
- The jury found Robinson not liable for breach of promise to marry, awarded Campbell the ring (or its value), and denied Campbell restitution.
- Post-trial motions (JNOV/new trial) were denied, and both parties appealed.

## Issues

1. Whether South Carolina recognizes a cause of action for breach of promise to marry.
2. Whether an engagement ring is a conditional gift and, if so, whether ownership depends on fault for ending the engagement.
3. Whether the jury instructions and verdict form improperly framed the legal standard for deciding ownership of the engagement ring.
4. Whether Campbell could recover restitution based on Robinson’s possession or retention of the ring.

## Decision

- The court affirmed the denial of Campbell’s directed-verdict motion on Robinson’s breach-of-promise counterclaim, holding the cause of action remains recognized in South Carolina.
- The court rejected a fault-based standard for engagement-ring disputes and held that fault has no role in determining ownership of an engagement ring.
- The court reversed based on erroneous jury instructions and verdict form tying ownership to fault and remanded for a new trial on Campbell’s declaratory-judgment and claim-and-delivery actions concerning the ring.
- The court reversed on Campbell’s restitution claim, concluding the record did not support restitution.
- The court affirmed in part, reversed in part, and remanded for further proceedings consistent with its rulings, including proceedings affecting the breach-of-promise claim and the ring-ownership claims.

## Legal Principles

- An engagement ring is a conditional gift given in contemplation of marriage; if the marriage does not occur, the donor is entitled to return of the ring upon request under a no-fault approach.
- Consideration of fault is legally improper in allocating ownership of an engagement ring when the marriage does not occur.
- Jury instructions and verdict forms must not predetermine dispositive legal elements or impose an incorrect legal standard that directs the outcome.
- Restitution (unjust enrichment) requires a non-gratuitous benefit conferred with circumstances supporting a reasonable expectation of compensation; a conditional gift relationship, without more, does not establish restitution.

## Conclusion

The court held that engagement rings are conditional gifts governed by a no-fault return rule, ordered a new trial due to fault-based instructions on ring ownership, confirmed breach-of-promise claims remain viable in South Carolina, and rejected restitution on the facts presented.


Campbell v. Robinson, 398 S.C. 12, 726 S.E.2d 221 (S.C. Ct. App. 2012)