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Keywords

damagesstatutetrialmotion

statutetrialwill

Related Cases

McGrath v. Dockendorf, 292 Va. 834, 793 S.E.2d 336

Facts

Ethan L. Dockendorf proposed to Julia V. McGrath on August 25, 2012, giving her a two-carat engagement ring valued at approximately $26,000. After their relationship deteriorated, Dockendorf broke off the engagement in September 2013, and the couple never married. Dockendorf filed an action in detinue to recover the ring, while McGrath demurred, claiming the action was barred by the heart balm statute. The trial court ruled in favor of Dockendorf, stating the ring was a conditional gift and ordered McGrath to return it or pay its value.

On August 25, 2012, Ethan L. Dockendorf proposed to Julia V. McGrath. She accepted. He offered her a two-carat engagement ring worth approximately $26,000. In September 2013, after the relationship deteriorated, he broke off the engagement.

Issue

Does the heart balm statute, Code § 8.01–220, bar an action in detinue for recovery of an engagement ring following the breakoff of the engagement?

The issue before us is one of statutory construction, which we review de novo.

Rule

The heart balm statute, Code § 8.01–220, prohibits civil actions for alienation of affection, breach of promise to marry, or criminal conversation, but does not address the law of conditional gifts.

In 1968, the Virginia General Assembly enacted Code § 8.01–220, which currently provides in subsection (A): Notwithstanding any other provision of law to the contrary, no civil action shall lie or be maintained in this Commonwealth for alienation of affection, breach of promise to marry, or criminal conversation upon which a cause of action arose or occurred on or after June 28, 1968.

Analysis

The court analyzed the heart balm statute and determined that it specifically targets certain civil actions, and does not encompass actions for the recovery of conditional gifts like engagement rings. The court distinguished between a detinue action, which seeks the return of specific property, and a breach of promise to marry action, which seeks damages for emotional distress. The court concluded that Dockendorf's action was valid as it was based on the principle of conditional gifts, not on a breach of promise to marry.

The primary objective in statutory construction is to determine and give effect to the intent of the legislature as expressed in the language of the statute. As a textual matter, Code § 8.01–220(A) bars three specific civil actions: (1) alienation of affection; (2) breach of promise to marry, and (3) criminal conversation. The statute says nothing about the law of conditional gifts.

Conclusion

The Supreme Court affirmed the trial court's decision, holding that the heart balm statute does not bar a detinue action for the recovery of an engagement ring given in contemplation of marriage.

The heart balm statute, Code § 8.01–220, does not bar a detinue action to recover conditional gifts, such as an engagement ring, that were given in contemplation of marriage.

Who won?

Ethan L. Dockendorf prevailed in the case because the court found that the heart balm statute did not apply to his action for the return of the engagement ring, which was classified as a conditional gift.

The trial court found as fact that the ring was given as a conditional gift in contemplation of marriage. The marriage did not occur. Consequently, we will affirm the judgment of the trial court.

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