In December of 2021, the Alabama Court of Civil Appeals released Hattaway v. Coulter, an opinion concerning engagement rings.
Believe it or not, engagement rings are often at the middle of divorce proceedings, and Hattaway goes to show just how important that first word is: engagement.
Hattaway and Coulter were involved in a romantic relationship for several years, and towards the end of their relationship began living together. Eventually, Hattaway dropped to a knee and asked Coulter to marry him, doing so with a $32,000, 2.5-carat diamond ring. Coulter said yes, and donned the ring on her left hand.
After a 9-month engagement, Coulter left the relationship, and took the ring with her. Hattaway asked Coulter to return the ring to no avail, eventually having his attorney send a letter to Coulter asking her to return the ring. Coulter did not return the ring, leading Hattaway to file a lawsuit against her based on claims of conversion, intentional infliction of emotional distress, and unjust enrichment.
The trial court sided with Coulter, dismissing Hattaway’s claims of conversion and intentional infliction of emotional distress, and ruling against Hattaway on his claim of unjust enrichment after conducting a bench trial. While Hattaway argued that the engagement ring was a
“conditional gift” that he was entitled to have back since the parties did not marry, the trial court disagreed.
However, not all hope was lost for Hattaway, as the Alabama Court of Civil Appeals sided with him. The Court of Civil Appeals held that this engagement ring was indeed a
“conditional gift,” meaning that the ring is “impliedly conditioned upon the marriage taking place. Until the condition underlying the gift is fulfilled, the attempted gift is unenforceable and must be returned to the donor upon the donor’s request.” In other words, an engagement ring does not become the property of the person that the ring was gifted to until the parties marry; the gifting of the ring is contingent upon the parties actually marrying. If they do not marry, the purchaser of the ring is entitled to get that ring back.
The division of marital property can be a tricky process, but in some situations, litigation might arise before the couple even marries.”
By Phil Fikes, Associate Attorney
