## Facts

- L.L. Stanard and Raymond J. Bolin began dating in October 1974.
- Bolin allegedly made assurances about substantial wealth and future support for Stanard, her children, and her mother, and promised that Stanard would not need to work.
- On September 22, 1975, Stanard accepted Bolin’s marriage proposal; Bolin purchased an engagement ring and matching wedding rings.
- The couple arranged a wedding for December 13, 1975, including reserving a church and minister, ordering dresses, and arranging a reception.
- They identified a home and signed a purchase agreement as “husband and wife.”
- At Bolin’s insistence, Stanard put her home up for sale, auctioned most of her furniture, and took steps at work consistent with leaving her position (including training a replacement).
- On November 13, 1975, Bolin told Stanard he would not marry her, allegedly causing illness, sleep and weight loss, and humiliation in canceling the wedding.
- Stanard sued for (1) pecuniary losses from wedding-related reliance, (2) pain, health impairment, humiliation, and embarrassment, and (3) loss of expected financial security from the anticipated marriage.

## Issues

1. Whether the common-law cause of action for breach of promise to marry should be abolished as contrary to public policy.
2. If the action remains available, whether damages may include loss of expected future financial security and other expectation interests from the contemplated marriage.

## Decision

- The Washington Supreme Court reversed the dismissal and remanded for trial.
- The court held the common-law action for breach of promise to marry remains viable and is not categorically contrary to public policy.
- The court limited recoverable damages to direct pecuniary losses proximately caused by reliance and to personal injuries such as mental suffering and related health impairment.
- The court barred damages for loss of expected future financial security or other speculative, long-term expectation benefits of the unrealized marriage.

## Legal Principles

- A claim for breach of promise to marry remains a recognized common-law action in Washington.
- Recoverable damages include reliance-based pecuniary losses proximately caused by the broken engagement (e.g., expenses and other measurable losses incurred in preparation for marriage).
- Recoverable damages also include reasonably provable personal injuries from the breach, including pain, impairment to health, humiliation, and embarrassment.
- Expectation damages for the anticipated long-term economic or social benefits of marriage (including “financial security”) are not recoverable because they are speculative and inconsistent with treating marriage primarily as an economic bargain.

## Conclusion

Washington preserved the breach-of-promise-to-marry action but narrowed its remedy: plaintiffs may seek compensation for reliance losses and demonstrable personal injuries caused by a broken engagement, but not for speculative expectations of future financial or social advantage from the proposed marriage.


Stanard v. Bolin, 565 P.2d 94 (Wash. 1977)