It is a story as old as time: man meets woman. They date, fall in love, discuss marriage, get engaged, break up and argue about who gets the $70,000 engagement ring.
Aside from the staggering sum, the case, now before the state’s highest court, has implications for any couple considering marriage – because there’s a chance their relationship could go down in flames.
Normally, the question of whether to keep the ring in Massachusetts is decided based on who was “at fault” for the broken engagement. But determining who was at fault in the case of Bruce Johnson and Caroline Settino is not a simple matter. The lower courts are confused and the question will be referred to the Supreme Court, which is expected to hear the case next month.
According to court documents, Johnson filed suit against his former fiancée Settino in January 2018 to recover an engagement ring he purchased at Tiffany’s in Boston for over $70,000. and two wedding rings, which he later purchased. The two became engaged in August 2017 at the Wequassett Resort and Golf Club in Harwich and planned a wedding for the following September.
Before the wedding, Johnson noticed “some disturbing traits” in his fiancée, he claims. In his Supreme Court complaint, he alleges Settino verbally harassed him in public, called him an idiot and “treated him like a child.”
Less than three months after the engagement, the filing states, the two got into an argument in which Settino said, “I’m a good-looking woman. I can get a man anytime I want.” Johnson searched Settino’s phone and found a text message to a man he had never met. It read, “My Bruce will be in Connecticut for three days. I need some free time.” Several voice messages complained that Settino had not seen the man often enough, the filing states.
When Johnson accused Settino of having an affair, she told him the man was her best friend for four decades and that “playing” was a euphemism between them for going out for drinks. A few weeks later, Johnson called off the engagement in a voicemail. He filed suit to reclaim the rings, and she countersued for money for the dental implant surgery Johnson had promised to pay for.
Engagement rings are a special type of “conditional gift” — that is, gifts given on the condition that something will happen — and fall into trickier territory than a general “no return” provision when something is given outright. Massachusetts courts typically look at both parties and stipulate that if the engagement is broken off “through no fault” of the giver, he or she can reclaim the ring.
The court concluded that Johnson’s decision to break off the engagement was “based primarily on his belief, albeit false, that Settino was having sexual relations with another man behind his back.” The separation was therefore his fault, the court said, which gave Settino the engagement ring and the one wedding ring she had bought for her, and also awarded her about $43,000 for the dental surgery, plus more than $20,000 in interest because the promised funds had been wrongfully withheld from her.
The appeals court, however, disagreed on the rings. The question was not whether Settino actually had an affair, but whether Johnson was justified or had sufficient cause to break off the engagement, the court wrote. “Sometimes you just can’t be blamed for it,” the appeals court wrote. One judge disagreed on how to define or determine blame in a broken engagement, and asked the Supreme Court to clarify that question.
Johnson was obligated to pay the cost of the dental surgery, the appeals court concluded, but the interest had been incorrectly calculated and would have to be recalculated from the time Settino filed the counterclaim.
The Supreme Judicial Council is scheduled to hear arguments in the case on September 6.
The question before the Supreme Court, according to a request for amicus curiae briefs, is whether Massachusetts courts should continue to use a “fault-based approach” to determine whether an engagement ring must be returned to the giver after a broken engagement. If not, the court asks, which rule is better?
According to the appeals court, most states now use a no-fault calculation, where a ring is a conditional gift that must be returned if the agreement is broken. Some states that use this approach are Iowa, New Jersey, Pennsylvania and Tennessee. A minority of states, such as Washington, use the traditional no-fault approach. At least one state – Montana – clearly views engagement rings as irrevocable unconditional gifts. In the remaining states, such as Rhode Island, what happens to the ring is an open question.
Settino argues that judges should not examine who was and who was not at fault for a broken engagement. A gift is a gift, even if it is an engagement ring, her lawsuit states. Applying a no-fault rule and assuming the ring is an unconditional gift “would eliminate judicial review of personal breakups and remove outdated and sexist stereotypes from the legal review of engagement gifts.”
Even if the court were to choose to calculate the conditional gift based on fault, she argues, Johnson gave her the receipts for the rings and signaled “that the gifts should be unconditional.”
She bristles at the appeals court’s justification analysis, citing a dissenting judge who said it was “inherently improper” for judges or juries to “judge matters of the heart.” In divorces and premarital separations, the courts are moving away from the fault and justification analysis, Settino argues.
Such an arrangement, Johnson said in his papers, “would undermine the meaning of an engagement ring and is unfair. The fairest approach would be to apply the no-fault gift rule, which requires the donor to get the ring back when the engagement ends.”
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