## Facts

- Rodger Lindh gave Janis Surman a diamond engagement ring in August 1993 when he proposed marriage; Surman accepted.
- Lindh purchased the ring for $17,400; its market value was found to be $21,200.
- The parties’ relationship deteriorated, and in October 1993 Lindh ended the engagement; Surman returned the ring.
- The parties reconciled, Lindh again proposed, and he again gave Surman the same ring in contemplation of marriage.
- In March 1994 Lindh again ended the engagement and demanded the ring’s return; Surman refused.
- Lindh sued for return of the ring or its value.
- An arbitration panel ruled for Surman; after a nonjury trial on appeal, the Court of Common Pleas entered judgment for Lindh for $21,200.
- The Superior Court affirmed, applying a no-fault rule requiring return of the ring when marriage does not occur.
- The Supreme Court of Pennsylvania granted review to decide whether return is required when the donor ends the engagement.

## Issues

1. Whether an engagement ring, as a conditional gift, must be returned to the donor when the marriage does not occur, even if the donor breaks the engagement.
2. Whether Pennsylvania should apply a fault-based inquiry (who ended the engagement and why) or a no-fault rule to determine recovery of an engagement ring.

## Decision

- The Supreme Court of Pennsylvania affirmed judgment for Lindh.
- The court held the engagement ring was a conditional gift with an implied condition of marriage.
- Because the parties never married, the condition failed and the donor was entitled to return of the ring or its value.
- The court adopted a no-fault rule: recovery does not depend on which party ended the engagement or the reasons for doing so.

## Legal Principles

- An engagement ring is a conditional gift; title becomes absolute only upon fulfillment of the condition.
- The condition is the occurrence of marriage, not acceptance of the proposal or the existence of an engagement.
- When the marriage does not occur, the donor is entitled to return of the ring (or its value) regardless of fault.
- Courts should not conduct fault inquiries into failed engagements because such disputes are difficult to litigate fairly and tend to increase acrimony and speculative investigation into private conduct.
- A bright-line, no-fault rule provides administrable certainty and limits litigation over personal relationship breakdowns.

## Conclusion

Pennsylvania treats an engagement ring as a conditional gift conditioned on marriage; when the marriage does not occur, the donor may recover the ring or its value without any inquiry into who ended the engagement or why.


Lindh v. Surman, 560 Pa. 1, 742 A.2d 643 (Pa. 1999)