## Facts

- John J. Fierro proposed to Janan Hoel shortly before Thanksgiving 1987 and gave her a 1.37-carat diamond ring valued at about $9,000.
- The parties announced their engagement and began making wedding plans.
- They planned to live near Manhattan; Fierro arranged to purchase a condominium using funds borrowed from his parents, documented by mortgage contracts.
- Hoel refused to sign the mortgage contract presented to her, stating she wanted to discuss it with her father.
- After continued disagreement, Fierro ended the engagement in March 1988 and demanded return of the ring; Hoel refused.
- Fierro sued to determine ownership; the district court ruled the ring was an unconditional inter vivos gift because no express condition was stated at delivery.

## Issues

1. Whether an engagement ring is an unconditional gift upon delivery absent an expressly stated condition of marriage.
2. Whether an engagement ring is an impliedly conditional gift in contemplation of marriage that must be returned if the marriage does not occur, regardless of fault.

## Decision

- The Iowa Court of Appeals (en banc) reversed.
- The court held an engagement ring given in contemplation of marriage is an impliedly conditional gift conditioned on the subsequent marriage.
- Because the marriage did not occur, the condition failed and Hoel was required to return the ring to Fierro.

## Legal Principles

- An engagement ring is an impliedly conditional gift; the implied condition is that the parties marry.
- The donor need not state an express condition at the time of the proposal for the condition to apply.
- If the marriage does not occur, the donee must return the ring to the donor, without regard to which party ended the engagement or why.

## Conclusion

The court adopted a no-fault, implied-condition rule for engagement rings: the ring is given in contemplation of marriage, and when the marriage does not take place, the ring must be returned to the donor.


Fierro v. Hoel, 465 N.W.2d 669 (Iowa Ct. App. 1990)