DeFina v. Scott

195 Misc. 2d 75, 755 N.Y.S.2d 587, 2003 N.Y. Misc. LEXIS 126
CourtNew York Supreme Court
DecidedFebruary 14, 2003
StatusPublished
Cited by1 cases

This text of 195 Misc. 2d 75 (DeFina v. Scott) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DeFina v. Scott, 195 Misc. 2d 75, 755 N.Y.S.2d 587, 2003 N.Y. Misc. LEXIS 126 (N.Y. Super. Ct. 2003).

Opinion

OPINION OF THE COURT

Diane A. Lebedeff, J.

The parties, once engaged, sue and countersue on issues which arise from the termination of their engagement. The disputes concern the wedding preparation expenses, the engagement ring, third-party gifts and the premarital transfer of a one-half interest in the real property which was to be the [76]*76marital abode.1 The distinguishing feature of this case — that both parties were well-established professional adults who embarked upon preparations for a formal wedding paid for from their own funds, primarily acting upon clear plans regarding their engagement and the establishment of their eventual economic union — calls for application of contract-based theories to the maximum extent possible, a legally novel approach, but one particularly suited to couples of this type and to contemporary society.

Briefly, the plaintiff is a female nurse practitioner and the defendant is a male attorney with two prior marriages, each of which concluded in divorce. The parties became engaged in 2000. They planned a wedding in St. Patrick’s Cathedral and a reception at the United Nations Plaza Hotel and registered their gift lists at suitably luxurious merchant establishments. He purchased an expensive engagement ring at Tiffany & Co. It is undisputed that the couple agreed the female plaintiff would pay the wedding-related expenses and that, prior to the marriage, the male defendant would provide her with a one-half interest in a residence. The defendant transferred to plaintiff a one-half interest in the condominium apartment which he owned free and clear. In March of 2001, the engagement terminated in a flurry of heated actions, which are relevant only to the extent described below. In April of 2001, each party sued the other to seek a resolution of the issues remaining open between them.

Resolution of the economic aspects of the dissolution of an engagement starts with section 80-a of the Civil Rights Law, which was enacted in 1935 and abolished suit for breach of contract to marry, and section 80-b of the Civil Rights Law, which was enacted in 1965 and permits, but does not require, [77]*77a court to direct return of gifts given solely in contemplation of a marriage which did not occur. The history and interpretation of these New York statutes were fully explored in Gaden v Gaden (29 NY2d 80, 88 [1971]).2

The Diamond Engagement Ring

The court starts with application of the traditional principle of New York law holding that an engagement ring is the property of the male donor when an engagement is terminated (see, Gagliardo v Clemente, 180 AD2d 551 [1st Dept 1992]; Scheinkman, New York Law of Domestic Relations, Courtship: Engagement Rings, § 4:4, at 105 [West NY Practice Series 2002] [“Even prior to the enactment of the anti-heart balm legislation,” cases held that “(t)he donee of the ring receives, at the time of the gift, only the right of possession. Firm ownership passes only upon the performance of the marriage”]).

This rule applies only to a ring given as an engagement ring (id. at 106 [“If there were reasons other than a contemplated marriage why the gift was given, such as part of a birthday or holiday celebration, the ring may not be subject to return. Where there is a genuine dispute as to the circumstances under which the ring was given, a trial is necessary to determine the facts”]). Here, although Ms. DeFina stated that Mr. Scott later described the ring as a Valentine’s Day gift, the ring remained covered by his homeowner’s policy with Ms. DeFina’s explicit consent.3 Based upon the record as a whole, the court finds the parties agreed that the ring remained his property and no exception to the engagement ring rule is applicable.

[78]*78The ring vanished from Ms. DeFina’s lower Manhattan apartment shortly after the events of September 11, 2001, and Mr. Scott has been paid for its loss by his insurance company. The only determination necessary to resolve this item is a declaration that Mr. Scott may retain the insurance proceeds as his property.

Wedding Expenses and The Apartment

Ms. DeFina testified without contradiction that she and Mr. Scott agreed that, as self-supporting professionals, each would contribute toward their impending marital status by Ms. DeFina advancing wedding preparation expenses and Mr. Scott conveying to her a joint interest in his condominium apartment. The court heard the testimony of these two strong-willed, strong-minded, highly-educated, and sophisticated adults and is fully satisfied that this agreement was reached between them, likely after some hard bargaining, and that both performed pursuant to this agreement.4

Mr. Scott urges that, in addition to securing the value of the engagement ring, he should be restored to full ownership of his unit, and that Ms. DeFina should be left bearing the approximately $16,000 outlay for the canceled wedding.5 Commentators have examined this proffered scenario and have [79]*79concluded that women, who traditionally bear wedding expenses, are necessarily the economic losers in broken engagements. For example, Rebecca Tushnet in Rules of Engagement (107 Yale LJ 2583, 2618 [1998]), after an extensive review of applicable laws, concluded, “The shift to mandatory ring-return rules and the denial of women’s claims for restitution [for advanced wedding expenses] have combined to make premarital law unfavorable to women. Until courts and legislatures elaborate a better theory of what no-fault rules are supposed to accomplish, this regime will remain both unequal and unjustified.”

Ms. DeFina requests reimbursement on the basis of upholding a simple contract agreed to between the parties: that Mr. Scott agreed to give Ms. DeFina a half interest in his condominium, and her outlays were to be her contribution thereto. She may not retain the entire interest, for there was no separate and independent business basis for the transfer (see, Vasinkevich v Elm Drugs, 208 AD2d 522 [2d Dept 1994] [premarital transfer involved shareholder’s agreement, guarantee and other consideration and was not affected by dissolution of engagement]).

Under settled principles of New York law, a contribution to a premarital gift entitles the contributor not to the retention of the entire gift but to a lien against the asset to the extent of the contribution (Gaden v Gaden, supra', see, Hendrick v Tellier, 274 AD2d 944 [4th Dept 2000] [improvements to real property belonging to former fiancée support claim for lien, unjust enrichment and constructive trust]). Because this principle invokes the lien exception relating to recovery of gifts made in contemplation of marriage (Civil Rights Law § 80-b),6 **6 such a result does not fall within the prohibited cause of action of breach of a contract to marry (Civil Rights Law § 80-a), even [80]*80though wedding preparation expenses are a typical element of damages in an action for breach of contract to marry where such claims are recognized (see, J.P. Ludington, Measure and Elements of Damages for Breach of Contract to Marry, 73 ALR2d 553 [I960]).

The court finds no cognizable rationale for treating a contract regarding wedding expenses as significantly different from any other contract.

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Bluebook (online)
195 Misc. 2d 75, 755 N.Y.S.2d 587, 2003 N.Y. Misc. LEXIS 126, Counsel Stack Legal Research, https://law.counselstack.com/opinion/defina-v-scott-nysupct-2003.