## Facts

- Jerod Heiman purchased an engagement ring for $9,033 in August 1994.
- He gave the ring to Heather Parrish as an engagement ring in contemplation of their marriage.
- The engagement ended in October 1995; Heiman ended the relationship.
- Parrish refused to return the ring.
- Heiman filed an action in April 1996 seeking return of the ring.
- The parties stipulated that the ring was given in contemplation of marriage and that neither party stipulated to whose fault caused the relationship to terminate.
- The dispute centered solely on ownership of the engagement ring after the marriage did not occur.

## Issues

1. Whether an engagement ring given in contemplation of marriage is a conditional gift, with marriage as the condition precedent to the recipient’s ownership.
2. Whether the donor’s right to recover the ring after a broken engagement depends on which party ended the relationship or who was at fault.
3. Whether Kansas should apply a fault-based approach or a no-fault approach to ownership of an engagement ring when an engagement is terminated.

## Decision

- The Kansas Supreme Court affirmed the district court’s judgment ordering Parrish to return the engagement ring to Heiman.
- The court treated the case as a question of law decided on stipulated facts and reviewed the legal conclusions without deference.
- The court held that, unless a contrary intent is shown, an engagement ring is a conditional gift given in contemplation of marriage.
- Because the marriage did not occur, the condition precedent failed and the donor was entitled to the ring’s return.
- The court adopted a no-fault rule: who ended the engagement, and fault for the breakup, is ordinarily irrelevant to ownership.
- The court noted a narrow possibility of departure from the no-fault rule only in extremely gross and rare situations.

## Legal Principles

- Unless a contrary intent is expressed, an engagement ring is presumed to be a conditional gift made in contemplation of marriage.
- The marriage itself is the condition precedent to the recipient’s permanent ownership of the engagement ring.
- When the engagement is broken and the marriage does not occur, the donor is ordinarily entitled to return of the ring.
- Fault-based inquiries into which party caused the breakup are generally not relevant to entitlement to the ring under the no-fault rule.
- Courts may avoid intrusive and difficult fault determinations in relationship disputes by applying a predictable conditional-gift rule, subject only to rare exceptional circumstances.

## Conclusion

Kansas treats engagement rings as conditional gifts dependent on marriage; when the marriage does not occur, the ring generally must be returned to the donor regardless of which party ended the engagement or who was at fault, with only a narrow, exceptional carveout for extremely egregious circumstances.


Heiman v. Parrish, 942 P.2d 631 (Kan. 1997)