Plaintiff, relying on defendant's proposal of marriage, trained a replacement for her job, placed her home for sale, sold her furniture, and incurred normal expenses incidental to a future union. One month before the date of marriage, defendant informed plaintiff he would not fulfill his promise of marriage; she subsequently became ill, repurchased her home furnishings, and cancelled all wedding plans. Plaintiff brought suit for breach of promise to marry, seeking damages for (1) direct pecuniary losses; (2) pain, impairment to health, humiliation, embarrassment; and (3) loss of the expected financial security of marriage. The superior court dismissed the complaint for failure to state a claim upon which relief could be granted. In a seven to two decision, the Washington Supreme Court reversed and remanded for trial, modifying the remedy of the cause of action to exclude damages for loss of future financial security. Stanard v. Bolin, 88 Wn. 2d 614, 565 P.2d 94 (1977).
D. J. Hurson,
Domestic Relations—Breach of Promise to Marry: Relic Revisited to Exclude Expectation Damages—Stanard v. Bolin, 88 Wn. 2d 614, 565 P.2d 94 (1977),
53 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol53/iss4/8