Spinnell v. Quigley
In Spinnell v. Quigley, 56 Wn. App. 799, 785 P.2d 1149 (Wash. Ct. App. 1990), the Court of Appeals of Washington explained that the fault rule is premised on a contract theory, with the engagement ring symbolizing an agreement to wed. (785 P.2d at 1150.)
If, due to a breach by the donor, the agreement is not fulfilled, "the donor should not benefit from that breach by regaining the ring."
The Spinnell court went on to explain:
On principle, an engagement ring is given, not alone as a symbol of the status of the two persons as engaged, the one to the other, but as a symbol or token of their pledge and agreement to marry. As such pledge or gift, the condition is implied that if both parties abandon the projected marriage, the sole cause of the gift, it should be returned. Similarly, if the woman, who has received the ring in token of her promise, unjustifiably breaks her promise, it should be returned.
When the converse situation occurs, and the giver of the ring, betokening his promise, violates his word, it would seem that a similar result should follow, i.e., he should lose, not gain, rights to the ring . . . "no man should take advantage of his own wrong."