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Massachusetts Court Rules Engagement Ring Must Go Back to the Donor When the Wedding Is Called Off, Regardless of Fault

Massachusetts' highest court ruled that a $70,000 engagement ring must be returned to the donor when the wedding does not happen, regardless of who ended the engagement.
From TheFinanceBase Team5 min to read
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In Massachusetts, an engagement ring given in contemplation of marriage must be returned to the donor when the planned wedding does not happen, and who ended the engagement no longer matters. The Massachusetts Supreme Judicial Court reached that conclusion in Johnson v. Settino, decided November 8, 2024, in a dispute over a $70,000 diamond ring. The rule is Massachusetts law. It is not a nationwide rule, and the sources reviewed for this article do not show whether a later statute or appellate decision has changed it since then.

What the court decided

The court changed the test. Massachusetts had long asked whether the donor was “without fault” before letting him or her recover an engagement ring. The Supreme Judicial Court dropped that question. Under the new rule, the failed condition is what controls: the marriage was the reason for the gift, the marriage did not happen, so the ring goes back to the donor. Fault in ending the engagement is not the deciding factor.

The court stated the principle in plain terms: “Where, as here, the planned wedding does not ensue and the engagement is ended, the engagement ring must be returned to the donor regardless of fault.” The opinion, written by Justice Wendlandt, also framed the question it was answering: whether “who is at fault” should continue to govern rights to engagement rings given in contemplation of marriage when the anticipated wedding does not come to pass.

The court applied the same rule to a wedding band that Johnson gave Settino. On a separate counterclaim by Settino over promised dental procedure costs, the court held that prejudgment interest had to be recalculated from the date of her counterclaim and sent that calculation back to the trial court. The dental claim is a different question from the ring, and the ruling on it does not affect who owns the jewelry.

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How the case reached the high court

  1. 2016: Bruce Johnson and Caroline Settino begin dating.
  2. Engagement: Johnson gives Settino a diamond engagement ring valued at $70,000, and later buys two wedding bands costing about $3,700 combined, as reported by the Associated Press in 2024.
  3. Breakup: Johnson ends the engagement after finding messages on Settino’s phone that he read as evidence of infidelity. Settino said the man was a friend.
  4. Trial court: The judge found no evidence that Settino was having an affair. The judge found that Johnson ended the engagement because of a mistaken belief, and initially let Settino keep the engagement ring and one wedding band.
  5. Appeals Court: The Massachusetts Appeals Court reversed on the rings.
  6. Supreme Judicial Court: The high court granted further appellate review, rejected the fault test, and ordered the ring and band returned to Johnson.

The trial judge’s finding matters for reading the case correctly. The court never found that Settino had an affair. Johnson’s suspicion was real to him, but the outcome does not turn on whether his suspicion was justified. It turns on the fact that the wedding did not happen.

Why the old fault rule was dropped

The older Massachusetts approach traced back to De Cicco v. Barker (1959). It governed engagement gifts for more than six decades. Under it, a donor could recover the ring only if he or she was without fault in the breakup. Critics of that approach argued that it required courts to relitigate the relationship, sorting out who said what and who was to blame, before deciding who owned a piece of jewelry.

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The Supreme Judicial Court said it was following what it described as the modern trend among jurisdictions that had considered the question. Harvard Law School professor Rebecca Tushnet offered a counterpoint to the Associated Press: “I’m a bit disappointed that they didn’t give more consideration to the other no-fault option. That would be that the gift stays with the person who received it, as is standard for most gifts.” Her point is that the court could have chosen a different no-fault rule, one that treats the ring like most other gifts and lets the recipient keep it, instead of the return-to-donor rule it adopted.

What the ruling does and does not cover

  • Covered: engagement rings and wedding bands given in contemplation of a marriage that does not take place, under Massachusetts law.
  • Not covered by the holding: a ring given with no marriage in view, a ring a couple later agreed to keep, and claims for other property or promised payments, which are decided on their own facts.
  • Not a damages award: the $70,000 figure is the ring’s reported value. The remedy was return of the property, not a payment of that amount.
  • Not gender-specific: the court’s rule does not depend on whether the donor is a man or a woman. In this case the donor was the man and the recipient was the woman, which is why the headline names her.

How other states handle engagement rings

Massachusetts is not the only state to address this question, and the answers differ. New York’s Appellate Division, in Rambod v. Tazeh (2020), also affirmed the return of a ring given in contemplation of marriage after a wedding was canceled. That decision applied New York law and discussed New York Civil Rights Law § 80-b. It is useful context, but it does not show that every state reaches the same result by the same route.

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The table below compares the two decisions on the points that most often decide these disputes. Where the sources reviewed for this article do not address a point, the cell says so.

Question Massachusetts (Johnson v. Settino, 2024) New York (Rambod v. Tazeh, 2020)
Ring treated as a conditional gift tied to the marriage? Yes. The planned marriage not occurring requires return. Yes. The ring was returned after the wedding was canceled.
Does fault or who ended the engagement matter? No. The fault test was abandoned. Not stated in the sources reviewed for this article.
Did the parties have a separate agreement or a later completed gift? Not the basis of the holding. Not stated in the sources reviewed for this article.
Does the dispute also involve wedding bands or other claims? Yes. The band was covered, and a dental-cost counterclaim was remanded for interest. Not stated in the sources reviewed for this article.
Which law governs? Massachusetts law. New York law, including Civil Rights Law § 80-b.
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What to take from this if you are in a similar situation

  • Check which state’s law governs. The rule above is Massachusetts law, and a court in another state may apply different reasoning.
  • Expect the question to be “was the marriage planned and did it fail,” not “who was to blame.” That is the question Massachusetts courts now ask for rings.
  • Keep records of the gift, its value, and the wedding plans, since disputes over rings often depend on what the couple intended when the ring changed hands.
  • Treat other claims separately. A ring dispute can sit alongside claims for shared expenses or promised payments, and each may be decided under different rules.
  • Confirm the current law before relying on it. The decision is from November 8, 2024, and the sources reviewed for this article do not show whether it has been altered since.

The decision is best read as a clear answer to one narrow question. In Massachusetts, a conditional engagement gift goes back to the donor when the wedding fails, and the fault of either party does not change that outcome.

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Sources: Massachusetts Supreme Judicial Court, Johnson v. Settino, SJC-13555 (November 8, 2024); Associated Press, Steve LeBlanc, “Revising the rules of engagement, court says jilted bride must give back $70,000 ring” (November 8, 2024); New York State Law Reporting Bureau, Rambod v. Tazeh, 2020 NY Slip Op 03382 (June 17, 2020).

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