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So far, we have touched on the issue of promises to marry under Maryland family law, but we haven’t yet covered all the salient cases which discuss this issue. Promises to marry are an interesting phenomenon: upon casual inspection, many non-legal experts might assume that these promises may be enforceable, but as we’ve learned generally such agreements are not enforceable under Maryland law.
This fact regarding the unenforceability of promises to marry undoubtedly shapes how unmarried cohabitants organize their lives. In certain instances, individuals have ended up being quite disappointed when they suddenly realize that their partner’s failure to follow through with a marriage promise basically will not carry any legal ramifications. In the case of Miller v. Ratner (1997), for example, a woman was disappointed when she split up with her long-term partner who had apparently given representations that he wanted to marry.
Let’s examine this case in detail to better understand the contours of promises to marry.
Facts of the Case
The couple in this case – Lonnie Miller and Warren Ratner – were involved in a long-term romantic relationship which included cohabitation. One of the critical facts regarding the relationship relates to sacrifices made by the Ms. Miller, and also certain representations made by Mr. Ratner. During the course of their relationship, Ms. Miller gave up her employment voluntarily, moved in with Mr. Ratner, and in many ways substantially altered her lifestyle in order to have a more functional relationship with Mr. Ratner.
Ultimately, Ms. Miller and Mr. Ratner parted ways, and subsequently, Ms. Miller brought a lawsuit against Mr. Ratner. In her complaint, Ms. Miller initially cited Mr. Ratner’s broken promise to marry as the basis for her suit, but she also contended that Mr. Ratner had engaged in intentional infliction of emotional distress, and that he gave another broken promise regarding general financial support.
Mr. Ratner filed for summary judgment and was successful.
Ruling & Analysis
The court first dealt with Ms. Miller’s claim regarding the breach of promise to marry: currently, Maryland’s proscription on such promises is codified under Md. Family Law Code Ann. § 3-102, and the court referenced this law in its opinion. Unless a person is pregnant, a breach of promise to marry will generally not be considered an actionable grounds for litigation. In this case, while the court may have acknowledged that such a promise was made, the court didn’t find a sufficient reason to broaden the scope of 3-102 and held that the promise in this particular was still unenforceable.
The court then addressed the other secondary claims added in Ms. Miller’s lawsuit. The court concluded that these additional claims (regarding emotional distress, financial fraud) were actually “repackaged” claims which were the equivalent of a claim for breach of promise to marry. In other words, Ms. Miller had simply identified aspects of the relationship which hadn’t worked in her favor and then attached them to her suit, but these aspects of the relationship weren’t necessarily grounds for a viable lawsuit. These determinations were made by the trial court and then affirmed by the appellate division (Court of Special Appeals).
In the end, Ms. Miller’s case simply didn’t warrant an exception to the standard principle in Maryland regarding the unenforceability of promises to marry. Had she hired a qualified family law attorney she may have avoided this failed suit.
Contact the Murphy Law Firm for More Information
If you would like additional information on the contours of promises to marry, the full legal ramifications of such promises, rare instances in which promises to marry may be enforceable, the basics of the Maryland divorce process, or any other pertinent family law matter, contact one of the family law lawyers at the Murphy Law Firm today by calling 240-219-1187.
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