## Facts

- Chad Clippard and Jamie Pfefferkorn dated for about four to five months in late 2002.
- On or about December 23, 2002, Clippard proposed marriage and gave Pfefferkorn a 2.02-carat diamond ring valued at about $13,500; she accepted.
- Around Christmas, the parties exchanged other gifts and socialized together.
- The relationship deteriorated, and around February 8, 2003, Clippard terminated the engagement roughly six weeks after it began.
- Clippard testified the ring was not a Christmas gift but a symbol of the engagement; he also testified the ring had been returned and re-given when the engagement was temporarily “off” and then renewed.
- Clippard admitted he ended the engagement because he knew he did not want to marry Pfefferkorn and was influenced by his family.
- Pfefferkorn refused to return the ring after the breakup; she maintained she was willing to marry and understood the ring at least partly as a Christmas gift.
- Clippard sued for return of the ring and damages; the trial court entered judgment for Pfefferkorn.

## Issues

1. Whether an engagement ring is a conditional gift given in contemplation of marriage that must be returned when the engagement ends.
2. Under Missouri’s fault-based approach, whether the donor may recover the ring when the donor terminates the engagement without fault by the donee.

## Decision

- The Missouri Court of Appeals affirmed the judgment for Pfefferkorn.
- The court applied the standard of review for a court-tried case, affirming unless there was no substantial evidence, the judgment was against the weight of the evidence, or the law was erroneously declared or applied.
- Missouri treats gifts in contemplation of marriage as conditional and revocable when the engagement is broken by the donee without fault of the donor.
- The trial court could find Clippard was at fault for ending the engagement and that Pfefferkorn was without fault; on that finding, Clippard was not entitled to the ring’s return or damages.
- Conflicting evidence about whether the ring was also a Christmas gift did not justify reversal because credibility and fact-finding were for the trial court.

## Legal Principles

- In Missouri, an engagement ring is generally a gift in contemplation of marriage and may be treated as conditional.
- Missouri applies a fault-based rule: the donor may revoke and recover the gift if the donee ends the engagement without fault on the donor’s part.
- If the donor terminates the engagement without fault by the donee, the donee may retain the ring.
- On appeal from a court-tried case, the judgment is presumed correct, and the appellate court defers to the trial court’s credibility determinations and resolves evidence consistently with the judgment.

## Conclusion

The court held that, under Missouri’s fault-based rule for gifts in contemplation of marriage and deferential appellate review of fact findings, Clippard could not recover the engagement ring because the trial court could reasonably find he ended the engagement without fault by Pfefferkorn.


Clippard v. Pfefferkorn, 168 S.W.3d 616 (Mo. Ct. App. 2005)