Maffe v. Loranger

Facts

P and D met professionally in 2013, and were platonic friends until January 2015, at which time they began a romantic relationship. P had been married previously, is now divorced, and has two children from his marriage. P spoke to D about the high costs associated with his divorce, including money spent on attorney’s fees, assets, and other related costs. D advised P that, should he remarry, he should have a prenuptial agreement to protect his assets. On August 13, 2015 P proposed marriage to D in Rhode Island, where P owned a second home. P gave D a six and one-half carat diamond ring worth approximately $132,000 at the time of their engagement. P had purchased the ring in New York City after the parties selected the diamond and designed the setting. P admitted: 'When I proposed I always said I'd marry for love and not a prenup. Unfortunately, I lost my way and didn't do it.' A few months later D moved into P's South Windsor home. They were to be legally married during a civil ceremony, conducted at home, and officiated by a family friend who is a justice of the peace. They then planned to travel to Italy with a small group of friends and family for a destination wedding ceremony and celebration. Their trip to Italy was to include a wedding ceremony, traditional wedding attire, photographs, a meal, and a party. P raised the issue of having a prenuptial agreement with D on several occasions. They were unable to agree on the terms of an agreement. P did not seek to have a draft agreement prepared by an attorney. The parties moved forward with their wedding plans. On Wednesday, June 8, 2016, they invited their friend, the justice of the peace, to their home in South Windsor to officially and legally marry them, as planned, prior to their scheduled trip to Italy. While D and her friends waited at the parties' home for P to arrive, P and D spoke on the phone as P was driving home. P expressed anxiety without having a prenuptial agreement in place. They decided to postpone the civil ceremony until the following Sunday and to, instead, utilize that time period to prepare a prenuptial agreement before they left for Italy the following week. As for not having an agreement, P cited 'procrastination and avoidance.' P said that he had wanted their lawyers to work out the agreement, rather than discuss terms with D directly because the conversations about the agreement always became emotional. Attorney Barall was asked to prepare an agreement. P and D agreed that the document was deficient. D did not believe that the terms of the agreement provided her with enough financial protection and security for her future. No agreement was reached at that time. On Saturday, June 11, 2016, the parties went to the Rhode Island house where they spent the day arguing. P informed D that he would not marry her without a prenuptial agreement in place, and then ended both their engagement and relationship. D then offered to return the engagement ring but P told her 'no, keep it. The ring is yours.' Despite the parties' breakup and the ending of their engagement, their prepaid trip to Italy remained scheduled for the following week. D decided to take the trip anyway, but with some of her family and her friends. D was at the airport, P called her to tell her that he had had a change of heart. P said that he loved D, that he had made a mistake, and that he still wanted to marry her. D agreed to reconcile and proceed with the ceremony and reception in Italy, despite the fact that these proceedings would not cause the parties to enter into a legally binding marriage. D did so based on P's assurance that the couple would be legally married and address the prenuptial agreement when they returned from Italy. P joined the defendant on the trip to Italy, and the parties went forward with a nonbinding wedding ceremony and celebration with family and friends. On their return, the coupled played husband and wife but they did not get legally married. A stormy relationship followed for the next two years. During this two-year period, P did not ask D to return the engagement ring. In November 2018, D announced she was leaving. P asked her to leave immediately but then regretted it and on November 13, 2018, P told her that he loved her and still wanted to marry her, but this time said that he no longer required a prenuptial agreement for them to get legally married. D was not amused and refused. Without warning, P seized her only car, a car that she believed belonged to her. In January 2019, P again regretted his decision and admitted that he was at fault for the parties' stormy relationship and, in particular, admitted fault for their June 2016 and November 2018 breakups. D did not respond. P sent D a text message in which he accused her of having a relationship and told her that he wanted her to return the engagement ring. P eventually brought the present action to recover the ring. P urges the court to adopt what has been termed the 'modern view,' where the ring 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. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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