A majority of judges and legal scholars are in agreement that all heart balm suits should be eliminated. Most states have enacted heart balm statutes that place limitations upon the amount of recovery. The abolition of heart balm suits does not, however, prevent either individual from recovering gifts made in contemplation of marriage. Many states have ruled that gifts, such as engagement rings, must be recovered if the promise to marry is revoked. Moreover, in Piccininni v. Hajus, 180 Conn. 369, 429 A.2d 886 (1980), Supreme Court of United States held that conditional gifts are not recoverable by the donor in all situations, however, if the engagement is broken. Under the traditional rule, if the donee breaks the engagement, or if the engagement is broken by mutual consent, the gifts must be returned.