
Jay Maffe, a successful Connecticut executive who invested $15m+ in a local pizza business, proposed to his fiance Heather Loranger.

He bought her a diamond ring, valued at $130k.
After experiencing turbulence in their relationship (which has all been aired out in the public record), the two decided to split.
At first, Maffe allowed Loranger to keep the ring. But then, after a fight, he rescinded his offer and demanded it be returned.
His now ex-fiance refused and kept the ring.
Maffe argued that the ring was given in exchange for the promise to get married. Loranger argued that even if that were true, Maffe said that she could keep it. She argued it was a gift.
Who do you think was right?
If you answered “yes”…
or if you answered “no”…
or even “it depends”…
They’re all right – to an extent. But the “rightest” answer is probably “it depends,” only because in law… outcomes are typically contingent on the specific facts of a case.
In this case, Loranger ended up winning. The court agreed that Maffe had given her the ring as a gift when he told her that she could keep it. Therefore, even if it was originally given in consideration for marriage, Maffe gifted it to Loranger when he agreed she could still keep it. – That’s the short answer, but keep reading!
Legal Analysis
Looking into this case I didn’t realize that these types of disputes over engagement rings are actually pretty common…Not only in Connecticut, but nationwide.
The legal implications are more nuanced than you may think.
In Maffe’s case, Maffe v. Loranger, the court idenfitied two common schools of thought when it comes to fiances who don’t return their engagement rings when a marriage falls through.
The first view is what the court termed as the “modern view.”
According to the modern view, when a ring is given to a fiance, it is deemed conditioned on the parties actually getting married and subsequent ownership is not based on which party was at fault for their not getting married.
Meaning, it wouldn’t matter who canceled the marriage, the person who bought the ring would be entitled to get it back.
The court stated: “The modern view is that the gift of the engagement ring is a conditional gift, the condition being the subsequent marriage of the parties. If the marriage does not take place, the condition has not been met and the ring should be returned to the donor.”
Older Connecticut cases adopted a fault-based approach, which dictates that whoever was at fault for breach of the promise to marry has to give the ring back.
So, if Loranger had called off the wedding, she’d have to return the ring because she breached the promise to marry. If Maffe called off the wedding, then Loranger would get to keep it.
The court stated: “The prevailing view in the United States and England, where an engagement is broken owing to the fault of the donor, he may not recover the ring … Decisions are based upon the theory that the ring is given upon an implied condition that the marriage will take place.”
So which standard did the court use, the modern or the fault based approach?
Neither, the court simply stated that the engagement ring was originally a conditional gift in contemplation of marriage, but when Maffe told Loranger later that she could keep it anyway, it transformed into an absolute gift. It was no longer conditional.
Lesson learned: Don’t tell your fiance to keep the ring after you split up. 🙂

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