Notable Items:
Appellant: Matthew Campbell
Appellee: Ashley Robinson
Venue: Court of Appeals of South Carolina
Issue(s) Before the Court:
Did the trial court err in denying Campbell's motion for directed verdict on Robinson's breach of promise to marry action?
Did the trial court err in denying Campbell's motion for directed verdict and JNOV on his claims?
Did the trial court err in overruling Campbell's objections to the jury charge and verdict form?
Did the trial court err in denying Robinson's post-trial motions for her breach of promise to marry action?
Appellant's Claim(s): Matthew Campbell
Claims South Carolina no longer recognizes breach of promise to marry.
Appellee's Claim(s): Ashley Robinson
Ring was converted to an outright gift by Campbell's telling her to keep the ring.
Holding(s) and Disposition:
Held:
Affirm trial court in denying Campbell's motion for directed verdict on Robinson's breach of promise to marry action.
Affirm trial court in denying Campbell's motion for directed verdict and JNOV on his claims.
The trial court erred in overruling Campbell's objections to the jury charge and verdict form.
The trial court erred in denying Robinson's post-trial motions for her breach of promise to marry action.
Disposition: Reverse regarding action for restitution and breach of promise to marry. Remand for new trial on Campbell's action for declaratory judgement and claim and delivery.
Material Facts:
- Campbell proposed and presented Robinson a ring in December 2005.
- Spring 2006, they agreed to postpone the wedding.
- Engagement later cancelled. (in dispute as to unilateral or bilateral)
- A full recounting of the facts is available below
Procedural History:
Rationale
Majority Opinion
- An engagement ring is a contingent gift. Must be returned to the donor upon request.
- Consideration of fault has no place in determining ownership of an egnmgaement ring.
- South Carolina's use of fault in dividing property does not mandate use of fault in this case.
- Restitution is an equitable remedy to prevent unjust enrichment.
- Plaintiff must show 1) nongratuitous benefit conferred; 2) defendant realized some value from the benefit; 3) would be inequitable for the defendant to retain the benefit without payment.
- Nongratuitous conferring requires: 1) at the defendant's request or 2) in circumstances where its reaonable to expect payment and is understood to be so by the defendant.
- Record does not support claim of restitution.
- Jury charge and verdict form 1) predetermined that the gift was conditional; 2) hinged ownership on fault.
- Entitled to new trial on this claim.
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- A full description of the rationale is available below