Randall v. Randall
Randall v. Randall
Opinion of the Court
Katharine Randall, the Former Wife, appeals from a final judgment of dissolution of her marriage to the Former Husband, Steven Randall. We agree with the Former Wife that the trial court erred in requiring her to return her engagement ring to the Former Husband after he had listed the ring as her nonmarital property. Accordingly, we reverse that portion of the judgment requiring the Former Wife to return the engagement ring to the Former Husband, and we remand for further proceedings consistent with our opinion.
This dissolution proceeding was filed in 2006 and was pending for two years before the trial court entered the final judgment. The parties were able to resolve most of their differences prior to trial. As a result, no party received alimony. By the time the trial court entered the final judgment, the parties had no joint assets and had placed liabilities into their individual names except for some liabilities relating to children’s expenses. Thus, the trial court was not required to perform any significant equitable distribution. Section 6 of the Final Judgment of Dissolution, entitled “Personal Property,” provides:
The parties have divided all personal property satisfactorily, with the exception of the [Former Wife’s] diamond engagement ring which was the Father’s family heirloom. Wife shall return this ring to the Husband, who shall not be entitled to sell the ring, but may keep it to give to his children as he sees fit.
Regarding this ring, the Former Husband’s financial affidavit lists an item labeled as “Grandmother[’]s Diamond Ring” as the Wife’s nonmarital property. The affidavit places the value on that ring at $6000.
The Former Wife argues that the engagement ring was given to her “in consideration of her agreement to marry” and that she received the ring before the marriage as part of the agreement she fulfilled when she married the Former Husband. She also maintains that the ring was her nonmarital property.
Section 61.075(1), Florida Statutes (2007), provides that “[i]n a proceeding for dissolution of marriage, ... the court shall set apart to each spouse that spouse’s nonmarital assets and liabilities.” The general rule is that an engagement ring is nonmarital property. See, e.g., Malone v. Malone, 929 So.2d 541, 541 (Fla. 1st DCA 2006); Rosen v. Rosen, 738 So.2d
The trial court in this case did not actually treat the ring as part of an equitable distribution scheme. Instead, it treated the ring as an “heirloom,” which the parties should not sell, but rather should give to the children as the Former Husband saw fit.
. The two children of this marriage are both females, and it is unclear what, if any, plan the Husband had for the distribution of this ring.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.