promise action: Campbell v Robinson, 398 S.C. 12, 726 S.E. 2d 221 (Ct. App. 2012). About one-half of U.S. states still permit such lawsuits, according to the National Paralegal College. Examples of such suits include a jury award of $150,000 in the 2008 Shell case in Georgia, and $130,000 in a North Carolina jury trial December 17, 2010, in the case of Dellinger v. Barnes (No. 08 CVS 1006). Laws vary by state. In Illinois, for example, documented wedding expenses can be recovered, but damages for emotional distress are prohibited, and notice of an intent to sue must be provided within three months of the engagement being dissolved. Determining damages Damages were generally permitted for expenses incurred on the expectation of a marriage, such as property transferred or wedding expenses. In some jurisdictions, emotional distress, loss of social standing, and loss of virginity were also possible sources of damages. Some countries also allowed the woman to sue for loss of future income, that is, for money that she would have had, if her very wealthy fiancé had not broken off the engagement. In 20th-century reforms, this was generally abolished over fears of gold digging. One challenge in settling disputes for breach of promise was determining whether a gift made during the engagement was an absolute gift—one given permanently, with no strings attached—or a conditional gift, given in the expectation of the marriage taking place. If an engagement gift was given on a holiday, such as Valentine's Day or Christmas, the gift could be considered to be non-contingent, and given partially for reasons other than marriage, and thus does not have to be returned. Christmas presents are generally taken to be absolute gifts, and thus cannot be recovered if the engagement dissolves, but engagement rings are generally taken to be conditional gifts, at least under most circumstances, which means that they must be returned if the recipient no longer chooses to go through with the marriage. Whether an engagement ring must be returned if the giver breaks off the engagement varies. Similar actions in law Criminal conversation was a similar tort, arising from adultery, in which a married person could sue the person with whom his or her spouse had engaged in adultery. Alienation of affections was another similar tort against a third party who encouraged the adultery, or who was otherwise responsible for the breakdown of the marriage. Non-common-law jurisdictions