hand but modern practice varies considerably. Legal ownership Tradition generally holds that if the betrothal fails because the man himself breaks off the engagement, the woman is not obliged to return the ring. This reflects the ring's role as a form of compensation for the woman's damaged reputation. Legally, this condition can be subject to either a modified or a strict fault rule. Under the former, the fiancé can demand the return of the ring unless he breaks the engagement. Under the latter, the fiancé is entitled to the return unless his actions caused the breakup of the relationship, the same as the traditional approach. However, a no-fault rule is being advanced in some jurisdictions, under which the fiancé is always entitled to the return of the ring. The ring only becomes the property of the woman when marriage occurs. An unconditional gift approach is another possibility, wherein the ring is always treated as a gift, to be kept by the fiancée whether or not the relationship progresses to marriage. Recent court rulings have determined that the date in which the ring was offered can determine the condition of the gift. E.g. Valentine's Day and Christmas are widely recognized as gift-giving holidays in the United States and some other countries. A ring offered in the form of a Christmas present is likely to remain the personal property of the recipient in the event of a breakup. In most states of the United States, engagement rings are considered "conditional gifts" under the legal rules of property. This is an exception to the general rule that gifts cannot be revoked once properly given. See, for example, the case of Meyer v. Mitnick, 625 N.W.2d 136 (Michigan, 2001), whose ruling found the following reasoning persuasive: "the so-called 'modern trend' holds that because an engagement ring is an inherently conditional gift, once the engagement has been broken, the ring should be returned to the donor. Thus, the question of who broke the engagement and why, or who was 'at fault,' is irrelevant. This is the no-fault line of cases." Though in certain states, whether a judicial action can be maintained at all to require return of an engagement ring is blocked by statute, as many states have statutes which state that no civil action shall be maintained for breach of promise to marry.<ref> See Also Cal. Civ.Code § 43.4, CONN. GEN. STAT. (2011) §