The Utah Court of Appeals issued a new decision on this alimony issue. The main issue was that of the pre-divorce standard of living and the concept of equalization of the post-divorce standards of living rather than just going on the recipient's needs. The trial court erred in not establishing the base standard of living, instead going to simply the needs of the parties. The trial court's decision was vacated and the case remanded for the trial court to reassess its alimony award.The case is Rule v. Rule.
The Virginia case of McGrath v. Dockendorf, ruled that a man may recover an engagement ring following a break off of the engagement. Virginia did have the policy that the engagement ring could be returned under the common law of conditional gifts. However this case proceeded under the concept of detinue.