.webp)
Broken promises to marry are as old as the institution of marriage itself. Historically, broken promises to marry someone have often had legal implications, but those are largely gone today. In other words, in nearly all cases today, when someone breaks a promise to marry, that promise will not lead to any legal repercussions. Promises to marry are highly personal things, and so the law is restricted in how it handles these types of very personal interactions. But, even today, promises to marry still may carry legal repercussions, although the circumstances in which a promise to marry may hold legal weight are quite limited.
In the case of Wallace v. Hawk (2025), the plaintiff brought a case in which FL Section 3-102 was cited. This statute is the last remaining statute which recognizes a claim based on a promise to marry. Let’s examine this case in greater detail to see how this statute operates under current Maryland law.
Facts of the Case
The plaintiff and the defendant were involved in a long-term romantic relationship. The two began dating in January of 2016, and then by April of 2016 the defendant allegedly made representations to the plaintiff that he had serious intentions. According to the plaintiff’s claim, the defendant stated that he wished to marry her in the future, but wanted to purchase a house together first. The defendant essentially “convinced,” or induced, the plaintiff to purchase a home in her name, and then the defendant allegedly stated that he would contribute 50% of the down payment at a later date, and also that he would contribute 50% toward the mortgage when he moved in. The defendant was a licensed real estate agent, and offered to act as the agent when the plaintiff made the purchase.
The plaintiff purchased a house, and used the defendant as agent. Importantly, the defendant received a commission from this transaction, although that commission wasn’t paid directly from the plaintiff. After the purchase, the relationship between the two parties unraveled, and ultimately the defendant withdrew his promise to marry.
The plaintiff brought a claim based on several distinct theories (or “causes of action”). The plaintiff argued that the defendant committed fraud and breach of fiduciary duty, citing FL Section 3-102; the plaintiff also argued that the defendant had been “unjustly enriched.” The defendant moved for summary judgment and won at the trial court level. The plaintiff then appealed.
Ruling & Post-Ruling Discussion
The plaintiff was successful at the trial court level. The trial court had actually summarily ruled against the plaintiff on all her three separate causes of action. On the issue of the applicability of FL Section 3-102, the appellate court made it clear that, in actuality, this section would not apply to the current set of facts as outlined by the plaintiff; however, the appellate court determined that the plaintiff’s claims based on fraud and breach of fiduciary duty should’ve survived summary judgment because the plaintiff didn’t need to rely on Section 3-102. Even though the defendant’s behavior did involve a promise to marry, the plaintiff still could claim that the defendant’s behavior was fraudulent, and a breach of fiduciary duty, even without citing Section 3-102. In other words, although the plaintiff cited Section 3-102, the facts described by the plaintiff could sustain a claim even without potentially fitting under this particular statute.
This case was complex, and the court spent copious energy going over the precise reasoning as to why the plaintiff’s claim should’ve survived. Perhaps the core point to take away is that the applicability of FL Section 3-102 is very narrow, and so those looking to cite this statute as a way to handle a broken promise to marry will likely need to rethink their legal strategy.
Contact the Murphy Law Firm for Additional Information
If readers would like to know more about promises to marry, the basics of filing for divorce, the limits of FL Section 3-102, or any other related family law matter, contact one of the family law attorneys at the Murphy Law Firm today by calling 240-219-1187.
.png)
.png)
.png)
.png)
