Engagement Ring – Conditional Gift

Hattaway v. Coulter, [Ms. 2200502, Dec. 17, 2021] __ So. 3d __ (Ala. Civ. App. 2021). The court (Thompson, P.J.; Moore, Edwards, Hanson, and Fridy, JJ., concur) reverses the Baldwin County Circuit Court’s bench verdict dismissing Terell Hattaway’s unjust enrichment claim predicated on Valeri Coulter’s refusal to return a $32,000 engagement ring after Coulter ended their relationship. Noting that the circuit court’s ore tenus judgment found that the ring was an engagement ring, the court holds

In light of our holding that, as a matter of law, an engagement ring is a gift conditioned upon the fulfillment of marriage, when Coulter ended her relationship with Hattaway the condition of marriage was not fulfilled and Hattaway was entitled to the return of the engagement ring. Undisputed evidence was presented demonstrating that it was Coulter who broke off the relationship with Hattaway, that they did not marry, and that, when Hattaway asked Coulter to return the engagement ring, she refused.

Ms. **18-19. The court also rejects Coulter’s argument “that the passage of two and one-half months between the end of the relationship and Hattaway’s formal request for the return of the engagement ring was unreasonable.” Ms. *19.

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