Page 18 - BusinessWest February 17, 2025

No Wedding, No Ring
Massachusetts Highest Court Overturns 60-year Precedent
BY ALEXANDRE P. PEREIRA, ESQ.
“A failed engagement that prevented in what all likelihood would have been a failed marriage is not a situation where a court should be required to impute blame to one party.”
In a recent decision, the Massachusetts Supreme Judicial Court
The facts of Johnson v. Settino embody the tumultuousness (SJC) created new legal precedent surrounding the return of
of modern relationships. In the summer of 2016, Johnson began engagement rings when the engagement ends and the planned
dating Settino. Over the course of their relationship, he showered wedding does not ensue. The court’s ruling in Johnson v. Settino
her with lavish gifts of jewelry, clothing, shoes, and handbags. A abolishes a six-decade-old, fault-based analysis, paving the way for a
year later, Johnson proposed to Settino with a $70,000 diamond more contemporary standard for ownership in such cases.
engagement ring.
In 1938, Massachusetts took its stance on the extent to which
In November 2017, Johnson discovered text messages on Set- courts would resolve disputes arising from private relationships.
tino’s phone indicating an intimate relationship with another man. Massachusetts enacted the Heart Balm Act, which prohibited
Following this discovery, he terminated the engagement. Johnson plaintiffs from seeking compensation for emotional damages stem-
subsequently sought the return of the diamond engagement ring ming from the end of a romantic relationship. Specifically, breach-
and wedding bands.
es of contracts to marry will not be causes of action recognized by
At trial, the judge ruled that Johnson had given the rings on the courts in the Commonwealth (M.G.L. c. 207, §47A).
condition of marriage but held him at fault for the breakup due to In 1959, the case of De Cicco v. Barker marked a significant
his unfounded suspicions of infidelity. Settino was awarded the moment in this legal landscape. De Cicco held that engagement
engagement ring and wedding band. After an appeal to the Mas- rings were, in essence, “pledges given on the implied condition
sachusetts Appeals Court, the trial court’s judgment was reversed that the marriage take place,” meaning that the Massachusetts
after holding that ending an engagement does not inherently
Heart Balm Act would not preclude actions for the recovery of an
assign blame to that party. The Appeals Court concluded that John- engagement ring. The decision was rooted in principles of equity,
son’s actions were reasonable, and the case was ultimately heard aiming to prevent the person who received the ring from becoming
by the Massachusetts Supreme Judicial Court.
unjustly enriched when the engagement fails. De Cicco created a
The SJC’s ruling in Johnson v. Settino overturned the fault- fault-based analysis, allowing the donor to reclaim the ring only if
based standard that stood firm for the better half of a century.
the engagement ended without any fault of their own.
Although the standard was equitable in theory, time has shown Over the years, jurisdictions across the country have shifted
the standard to be less practicable. Engagements often fail with- away from the fault-based approach. Until recently, Massachusetts
out clear fault by either
had not revisited this standard — until the SJC took up Johnson v.
party. An engagement
Ring
Settino.
period can be, and per-
Continued on page 25
>>
CELEBRATING 130 YEARS
Est. 1895
Your trusted legal resource for individuals, families, businesses, and municipalities.
Accidents and Injuries
SPRINGFIELD
Banking and Commercial Finance
Bankruptcy and Reorganization
Business and Corporate
Cannabis
Civil Litigation
Domestic Relations and Family Law
Criminal Litigation
AMHERST
SPRINGFIELD
Elder Law
Employment Law
Landlord and Tenant Issues
Land Use / Zoning / Environmental Mediation and Alternative Dispute Resolution Municipal
Real Estate
Special Needs Care Planning
Trusts and Estates Planning
Workers Compensation
INGFIELD AMHERST NORTHAMPTON
413.781.0560 BA
SPR
SPRINGFIELD
WESTFFIEIELLDD
CON
leb
Your mun
A
M
H
E
R
S
T
A
BAC
M
H
ER
S
T
413.781.0560
NORTHAMPTON
NORTHAMPTON
Ce
WILSON.COM
SPRINGFIELD
413.781.0560 \ www.baconwilson.com 413.781.0560 BACONWILSON.COM
Celebrating 130 Years | Est. 1895
Your trusted legal resource for individuals, families, bu municipalities.
Accidents and Injuries
Domestic Relat Celebrating 130 Years |BaEnksintg.a1nd895
and Family La Commercial Finance
Elder Law Bankruptcy and
Employment L Your trusted legal resource for inRdeiovrigdaunaizlsa,tifoanmilies, businesses, and Landlord and T municipalities.
Business and Corporate
Cannabis
Land Use/Zoni WESTFIELD Civil Litigation Environmental Accidents and Injuries Domestic Relations M ORTHAMPTON
Banking and Criminal Litigation R and Family Law Mediation and Commercial Finance
Celebrating 130 Ye Elder Law Dispute Resolut ILSON.COM
Bankruptcy and
Employment Law S Reorganization
Landlord and Tenant Issues Pl Your trusted legal resource Business and Corporate
municipalities. Tr Cannabis
Land Use/Zoning/ Pl Civil Litigation
Environmental Accidents anWd WESTFIELD
Criminal Litigation
Mediation and AltBeranaktinvge andC ing 130 Years | Est. 1895
Dispute ResolutionCommercial F Bankruptcy an Reorganizatio sted legal resource for individuals, families, businesses, and
alities.
Business and Cannabis Accidents and Injuries Domestic Relations
Municipal
Civil Litigatio AMHERST NORTHAMPTON
Banking and and Family Law
WESTFIELD
Real Estate
Criminal Litig Commercial Finance Elder Law
Employment Law
Special Needs Care 413.7B8a1n.0kr5u6p0tcyBaAndCONWILSON.COM
Planning
Reorganization
Landlord and Tenant Issues
Business and Corporate
Trusts and Estates
Cannabis
Land Use/Zoning/
Planning
Civil Litigation
Environmental
Workers
Criminal Litigation
Mediation and Alternative
Compensation
Dispute Resolution
18 FEBRUARY 17, 2025
<< LAW >>
BusinessWest
N ONW
rat
tru icip
sinesses,
ions w
aw
enant Iss
ng/ unicipal
Alternati eal Estat ars | ion pecial N anning for indi usts an anning
orkers Injuries ompensa inance
d n
Corporat
n
ation
v
E
e d
e