Return of Engagement Ring – New York Has Jurisdiction Over Runaway Brides

The engagement ring cases keep coming.

In the latest reported engagement ring case, Dreznick v Lenchner, the loving couple resided together in New York when they became engaged to be wed. A year and a half later, the woman ended the engagement and moved from the man’s residence with an engagement ring, a dog, and other items of personal property allegedly belonging to the man.  The jilted man demanded the return of the ring and other property and the woman, who had moved to California, refused. The man commenced suit and the woman sought to have the action dismissed, claiming a New York court lacked personal jurisdiction over her.

In a rather curious ruling, the Appellate Division found that personal jurisdiction was obtained on the cause of action for the return of the engagement ring under CPLR 302(b). That section grants a New York court  personal jurisdiction over non-residents and non-domiciliaries in "matrimonial actions."

As Thomas Swartz questions, since the parties were never married, how could CPLR 302(b) apply?
The Court  did not elaborate.  Perhaps, deliberately so, hoping that the "just" result would not be questioned. After all, this woman just did not want to return the ring.   She lost at the trial court level and appealed.  (It must have been some ring for them to spend that much money fighting about it.)

It is interesting that the appellate court took such an expansive view of the term matrimonial action.
I wonder if the court will take such an expansive view when it is confronted with a break up of a same sex relationship.

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