After reading the article again, I think the award was based on breach of promise, based on this:
I'd say, then, that the monetary damages were based on the value of the house . . . ?But the Court of Appeals of Georgia ruled on Nov. 22 to uphold the trial court's decision, saying the promise to marry is enforceable and the fact that the couple lived together before and after the marriage proposal is only collateral to the promise to marry.
For the record, I agree with the decision.