Vigil v. Haber
Supreme Court of New Mexico
888 P.2d 455 (1994)
Glenn Haber (plaintiff) and Jannel Vigil (defendant) exchanged engagement rings before their relationship deteriorated and the engagement was called off; a special hearing commissioner, while resolving a protection-order dispute between them, ordered the rings mutually returned, but while Haber complied, Vigil did not, prompting police to hold her ring pending trial-court resolution. The trial court held Vigil could keep her ring because Haber's own conduct had caused the engagement's failure, and Haber appealed.
Whether, under the modern rule, an engagement ring is a conditional gift that must be returned if the condition precedent of marriage does not occur, absent an express agreement to the contrary.