## Facts

- In 2015, Jay Maffe proposed marriage to Heather Loranger and gave her a diamond engagement ring valued at about $132,000.
- The couple planned a civil marriage ceremony in Connecticut for June 8, 2016, with plans for a later destination wedding in Italy.
- During the engagement, Maffe raised the need for a prenuptial agreement.
- Minutes before the June 8, 2016 civil ceremony, Maffe told Loranger he would not marry without a prenuptial agreement.
- The couple postponed the ceremony and began negotiating a prenuptial agreement.
- The negotiations and relationship continued for roughly two years, during which the parties broke up and reconciled several times.
- After the couple’s first breakup, Loranger offered to return the ring; Maffe told her to keep it and stated that the ring was hers.
- In November 2018, Loranger ended the relationship permanently and the parties did not marry.
- Maffe later sought return of the ring and filed suit in Connecticut Superior Court to recover the ring (or its value), claiming it was a conditional gift given in contemplation of marriage.
- Loranger defended on the grounds that (1) Maffe was at fault for the failed marriage, and (2) Maffe’s statements and conduct made the ring an unconditional gift.
- Loranger introduced a letter from Maffe in which he admitted his insecurities contributed to the relationship’s deterioration; Maffe also admitted at trial that he was at fault for key breakups.

## Issues

1. Whether the engagement ring was a conditional gift given in contemplation of marriage that had to be returned when the marriage did not occur.
2. Whether Maffe’s statement instructing Loranger to keep the ring converted the ring from a conditional engagement gift into an unconditional, absolute gift.
3. Whether Maffe’s fault for the failed marriage affected his ability to recover the ring.

## Decision

- The court entered judgment for Loranger and denied Maffe recovery of the ring.
- The court recognized the general modern view that an engagement ring is a conditional gift tied to the occurrence of marriage.
- Based on the evidence, the court found Maffe was at fault for the engagement’s failure, including his last-minute refusal to marry without a prenuptial agreement and his acknowledged role in the relationship’s breakdown.
- Independently, the court found that although the ring was conditional at the outset, it became an absolute gift when Maffe told Loranger to keep it and indicated it was hers.

## Legal Principles

- Engagement rings are commonly treated as conditional gifts given in contemplation of marriage; if the marriage does not occur, the donor may seek return of the ring under a conditional-gift theory.
- Courts take different approaches to broken engagements: some apply a no-fault rule (ring returns to donor if no marriage), while others consider fault in determining whether return is proper.
- A donor can waive or abandon the marriage condition by clear words or conduct, and a ring that began as conditional can become an unconditional inter vivos gift.
- Evidence bearing on donative intent and waiver includes statements such as telling the recipient to keep the ring, the parties’ conduct after breakups, and admissions reflecting responsibility for the engagement’s failure.

## Conclusion

The Connecticut Superior Court held that Maffe could not recover the engagement ring because the evidence showed he was responsible for the failure to marry and, in any event, his instruction that Loranger keep the ring reflected an intent to give it to her outright, converting the ring from a conditional engagement gift into an absolute gift.


Maffe v. Loranger, 2021 WL 782924 (2021)