PROMISE OF MARRIAGE

4 definitions found across Law Mind sources

PROMISE OF MARRIAGEAuthored
The Law Mind • 1104 words
Definition
A promise of marriage is a mutual contract between two persons — historically, a man and a woman — by which each agrees to marry the other at some future time. It is a genuine contract, not a mere expression of intent, and carried full contractual force at common law. Because a wedding cannot be agreed upon and celebrated simultaneously, every marriage is necessarily preceded by some express or implied agreement of this character. At common law, a broken promise of marriage gave the injured party a cause of action in contract, known as breach of promise to marry (or breach of promise of marriage), entitling them to recover damages. The remedy was treated as an action on the case sounding in contract, though courts also permitted recovery for emotional injury, social humiliation, and in some instances seduction — elements more characteristic of tort than contract. ---
Common Language
Modern common usage (Wiktionary): A proposal of marriage; an agreement or assurance given by one person to another that they will marry. Historical common usage (Webster's 1913): A pledge or engagement to marry; a betrothal. The gap between common and legal meaning is significant in one direction: ordinary usage treats a promise of marriage as a unilateral act — one person proposing to another. Legal usage requires mutuality. A promise of marriage in the legal sense is a bilateral contract; both parties must have agreed. A proposal alone, without acceptance, does not constitute a promise of marriage in law and cannot support a breach of promise action. ---
Common Confusion
Promise of marriage is sometimes conflated with betrothal or engagement. These concepts are related but not identical. A betrothal in historical law could carry quasi-sacramental weight and, in some ecclesiastical traditions, was treated as a near-equivalent to marriage itself. An engagement is the modern social term for the same arrangement. The legal term promise of marriage is the contractual frame applied when the relationship is litigated — when breach occurs and a damages action follows. Researchers should be alert to these three terms appearing interchangeably in historical sources while carrying distinct weight depending on whether the forum is civil, ecclesiastical, or equitable. ---
Why It Matters in Research
This term belongs almost entirely to a defunct cause of action. The breach of promise to marry suit was a staple of nineteenth-century common law litigation and generated an enormous body of case law and treatise commentary. Most American states abolished or severely curtailed the action through "Heart Balm" statutes enacted primarily between the 1930s and 1970s. A researcher encountering promise of marriage in pre-twentieth-century sources is working in active law; encountering it in modern sources almost always means they are reading about its historical abolition or navigating one of the few surviving jurisdictions. Several research traps follow from this history: First, historical sources treat this as a contract action, but the damages recoverable often exceeded pure contract measure — emotional distress, loss of social standing, and seduction damages blur the contract/tort boundary. Do not assume modern contract principles map cleanly onto historical promise of marriage cases. Second, the cause of action was heavily gendered in its practical application. While formally available to either party, the overwhelming majority of plaintiffs were women. Historical dictionary entries and treatises often implicitly assume a female plaintiff; researchers analyzing gender, damages, or procedural treatment should account for this asymmetry. Third, the implied promise of marriage matters as much as the express one. Bouvier notes that every marriage is preceded by an express or implied contract of this description. Courts regularly inferred a promise from conduct — prolonged courtship, public acknowledgment, cohabitation — without requiring any formal words. Searching only for explicit written promises will miss much of the relevant case law. Fourth, this term connects corpus-wide. The employment law literature on implied contract (promises made through conduct or policy) shares analytical structure with how courts inferred promises of marriage from behavior. The family law literature on proxy marriage and marriage by estoppel addresses what happens when consent and ceremony are separated — the same conceptual gap that gives the promise of marriage its legal existence. ---
Historical Dictionary Support
The three source dictionaries are in substantial agreement on the core definition: Bouvier and Black both frame the promise of marriage as a mutual contract, entered by a man and a woman, to marry each other. Bouvier elaborates most fully, noting both the structural necessity of such a contract (the temporal gap between agreement and ceremony) and the damages remedy available upon breach. Rapalje & Lawrence is the most useful for researchers, though its entry is organized around the broader mechanics of contractual promises rather than the promise of marriage specifically. Its insistence on mutuality — that a promise must be made in consideration of something done or to be done in return — is directly applicable: a promise of marriage is enforceable precisely because it is mutual, each party's promise serving as consideration for the other's. The cross-reference to covenant (promise under seal) is a reminder that in early English practice, formal betrothals could take a sealed form with different procedural consequences. What the historical dictionaries collectively miss: the tort dimension of breach of promise damages, the implied promise doctrine, and any treatment of the cause of action's eventual legislative abolition. Researchers relying on these sources alone will have an accurate picture of the action's structure but an incomplete picture of its rise, decline, and modern status. ---
Jurisdictional Note
Most U.S. states abolished the civil breach of promise to marry action by statute during the twentieth century. A handful of states retain it, sometimes in modified form. England substantially limited the action under the Law Reform (Miscellaneous Provisions) Act 1970. Researchers working across jurisdictions should verify current statutory status before assuming historical case law reflects live law. ---
Encyclopedia Cross-Reference
family_12: Marriage — Proxy Marriage and Marriage by Estoppel (The Law Mind Family Law Encyclopedia) — for the conceptual relationship between pre-ceremony agreement and the legal existence of marriage. employment_118: Breach of Implied Contract — Handbooks, Policies, and Promises (The Law Mind Employment & Labor Law Encyclopedia) — for comparative analysis of how courts infer binding promises from conduct without explicit agreement. ---
Related Terms
Breach of promise to marry Betrothal Engagement Heart Balm statutes Seduction (as a damages element) Contract (mutual consideration) Covenant Damages (expectation; emotional distress) Marriage Implied contract
PROMISE OF MARRIAGEmain
Black's Law Dictionary • 1891
tract mutually entered into by a man and a woman that they will marry each other.
PROMISE OF MARRIAGEmain
Rapalje & Lawrence • 1883
-See BREACH, 24. PROMISED, (in a declaration). 1 Chit. 619. (not necessary in a declaration in as- (in a will). Amb. 519. 3. Contractual promise-Mutual sumpsit). 3 Mass. 160. promises. To have legal effect a promise must either be under seal, when it forms a covenant (q. v.), or must form part of a contract, i. e. be made in consideration of something done or to be done in return by the promisee. (See CONSIDERATION; CONTRACTS.) When that consideration consists of another promise each party is both a promisor and a promisee, and the contract consists of mutual promises; thus, in an ordinary contract of sale, the vendor's promise to deliver the goods is in consideration of the purchaser's promise to pay for them, and vice versa.
PROMISE OF MARRIAGEmain
Bouvier's Law Dictionary • 1928
A con- tract mutually entered into by a man and a woman that they will marry each other. Every marriage is necessarily preceded by an express or implied contract of this de- scription, as a wedding cannot be agreed upon and celebrated at one and the same instant; Addison, Contr. 1196. When a man and a woman agree to mar- ry and subsequently either one refuses, the other may bring suit for damages, such suits being called breach of promise suits. It is no defence to an action for breach of promise that the defendant was married if the plaintiff did not have knowledge of such fact; 60 N. Y. Sup. Ct. 222; 133 N.Y. 623. If a man refuse to marry a woman she need not make a demand before bring- ing action; 77 Wisc. 663. Before the Ref- ormation no action for breach of promise could be maintained, for marriage was a matter of spiritual jurisdiction. It was not till the middle of the seventeenth cent- ury that marriage was recognized by our law as a temporal benefit, and a breach of promise as cognizable by the temporal courts; 20 Q. B. D. 494, 504, 505. A promise of marriage is not to be lik- ened to an actual marriage. The latter, as has been seen in the article on marriage, is not a contract, but a legal relation; while the former is an executory contract in the strict sense of the term, and gov- erned in general by the ordinary law of contracts, though it has certain peculiar- ities of its own. As in other contracts, the parties must be sui jurix. If, therefore, the man or the woman be an infant, or labor under any other legal disability, he or she will not be bound by a promise of marriage; but if one of the parties be an infant and the other be an adult, the prom- ise will be binding upon the latter; Stra. 937; 5 Cow. 475; 7 id. 22; 5 Sneed 659; 1 D. Chipm. 252; 42 Ill. App. 511. A promise made during infancy may be ratified after the infant attains majority. A late English statute requires a new and distinct con- tract, after majority, in order to bind the infant on his promise to marry after he comes of age; but a new contract may be inferred from continued acceptance of the engagement; L. R. 5 C. P. 410; and see 4 C. P. Div. 485. Neither does it follow, as we shall see presently, that a promise of marriage is not binding because the parties to the promise cannot form a valid mar- riage; they may be competent to contract, though not competent to marry. There must be a legal and valid consider- ation; but as there are always mutual prom- ises, they are a sufficient consideration for each other. There must be a meeting of the minds of the parties, i. e. a request or proposition on the one side, and an as- sent on the other. If the communications between the parties are verbal, the only questions which usually arise relate to evidence and proof. The very words or time or manner of the promise need not be proved, but it may be inferred from the conduct of the parties, and from the cir- cumstances which usually attend an en- gagement to marry: as, visiting, the un- derstanding of friends and relations, prep- arations for marriage, and the reception of the man by the woman's family as a suitor: 3 Salk. 16; 15 Mass. 1; 2 D. & C. 282; Leake, Contr. 210; 18 Pa. 831; 1 Ohio St. 26; 2 C. & P. 553; 6 Cow. 254; 26 Conn. 398; 4 Zabr. 291; 65 Vt. 273. But as to the evidence of a contract to marry, more direct proof is now commonly required than formerly, since modern statutes per- mit parties themselves to take the stand; Schoul. Husb. & W. § 43. Therefore a promise cannot be inferred from devoted attention, frequent visits, and apparently exclusive attention; 53 N. Y. 267; nor from mere presents or letters not to the point; see 2 Brewst. 487; [1891] 2 Q. B. 534; nor from the plaintiff's wedding preparations, unknown to the defendant; 48 Ind. 562; 68 Ill. 41; nor from the woman's unexplained possession of an engagement ring; 2 Brewst. 487. See, generally, 53 N. Y. 267. A later New York case holds that under the law allowing parties to an action to testify, a promise of marriage cannot be inferred from the mere proof of circum- stances such as usually attend an engage- ment to marry. In the absence of fraud, there must be proof of an actual contract; a meeting of minds of the two parties. Courtship alone or mere intention to marry is not enough. Thorough acquaintance with character, habits, and disposition is essential in order to enter into such a con- tract intelligently, and an opportunity must be allowed to form the acquaintance which is required, without raising the in- ference of a contract; 151 N. Y. 598. Mere courtship is not an agreement to marry; 14 Am. R. 111; 63 Am. Dec. 529; 63 IllI. 41. When the parties are at a distance from each other, and the offer is made by letter, it will be presumed to continue for a rea- sonable time for the consideration of the party addressed; and if accepted within a reasonable time, and before it is expressly fevoked, the contract is then complete; 1 Pars. Contr. 84. No particular

Explore the full Law Mind legal research platform.

SubscribeEncyclopediaSign In