In Michigan, courts have held that an engagement ring given in contemplation of marriage is an impliedly conditional gift that is a completed gift only upon marriage.[1] If the engagement is called off, the gift is not capable of becoming a completed gift and must be returned to the donor.
In re Estate of Lowe, the court opined that where a person in possession of an engagement ring has not broken the engagement at the time of her death or refused to marry, that person has a right to possession of the jewelry as against all persons and the ring’s donor has no right to claim the recovery of the engagement ring from the estate.[2]
[1] Meyer v. Mitnick, 244 Mich. App. 697 (Mich. Ct. App. 2001)
[2] In re Estate of Lowe, 146 Mich. App. 325 (Mich. Ct. App. 1985)