## Facts

- Glenn Haber gave Jannel M. Vigil an engagement ring in contemplation of marriage; Vigil gave Haber a ring as well.
- The relationship deteriorated, and the parties separated before marrying.
- In proceedings related to a temporary order of protection, a hearing commissioner directed that the parties return the rings to each other.
- Haber returned the ring in his possession and other items; Vigil refused to return her engagement ring.
- Police held Vigil’s ring pending resolution, and Haber moved in district court for an order releasing the ring to him.
- The district court found Vigil ended wedding plans due to Haber’s misconduct and ruled Vigil could keep the ring because Haber caused the condition (marriage) to fail.
- Haber appealed; the state supreme court accepted review, treating the dispute as sounding in contract for appellate-jurisdiction purposes.

## Issues

1. Whether an engagement ring given in contemplation of marriage is a conditional gift dependent on marriage.
2. Whether the donor’s right to recover the ring turns on which party was at fault for the broken engagement.
3. Whether the dispute is properly treated as contract-based for purposes of appellate review.

## Decision

- The court held the engagement ring was a conditional gift dependent on the parties’ marriage.
- The court held fault for the broken engagement is irrelevant to ownership of the ring.
- Because the marriage did not occur, the condition failed and the ring must be returned to Haber.
- The court vacated the district court’s order and remanded for entry of an order releasing the ring to Haber.

## Legal Principles

- An engagement ring given in contemplation of marriage is a conditional gift subject to an implied condition precedent: the marriage.
- When the contemplated marriage does not occur, the condition fails and the donee must return the engagement ring to the donor.
- Courts need not determine which party was responsible for ending the engagement; fault does not affect the return obligation.
- A dispute arising from a marriage proposal may be characterized as sounding in contract because marriage is a civil contract under state law, supporting appellate review on that basis.

## Conclusion

The court adopted a no-fault rule for engagement rings: because the ring is a conditional gift dependent on marriage, the donee must return it to the donor when the marriage does not occur, without litigating who was to blame for the breakup.


Vigil v. Haber, 888 P.2d 455 (N.M. 1994)