In Dellagrotta v. Dellagrotta (873 A2d 101 [RI 2005]), the groom's parents bought a house for their son and his bride. The parents kept title in their name. After the marriage broke down, the wife/bride claimed that the house was a gift to her, and she also maintained that she should be able to keep the house under theories of promissory estoppel and constructive trust. The Supreme Court of Rhode Island unanimously rejected the wife's claims of ownership and allowed her only a portion of the appreciation of the house's value based on improvements she made. In Dellagrotta, rejecting theories based on promissory estoppel, the court stated: "When a gift consists of real property, the donor must manifest his or her intent by delivering a deed to the parcel." (873 A2d at 110.) The court concluded that the statements made by the father of the groom/husband "did not manifest a clear and unambiguous promise to divest himself of dominion and control over the property." (Id.) Rejecting the claims based on constructive trust, the court noted: "Confidential or fiduciary relationships do not inherently exist between family members." (Id. at 111.) Each case is fact-specific, and the circumstances of each case must be analyzed to determine "whether a confidential or fiduciary relationship was at work." (Id.) The court found, in that case, that there was "no evidence establishing a pattern of [one party]'s reposing trust and confidence in the other party." (Id. at 112.)