R2d § 2
Promise; Promisor; Promisee; Beneficiary
(1) A promise is a manifestation of intention to act or refrain from acting in a specified way, so made as to justify a promisee in understanding that a commitment has been made.
Professor's notes
Elements of a promise: (1) a manifestation of intention; (2) to act or refrain from acting in a specified way; (3) so made as to justify the promisee in understanding a commitment has been made. The test is objective. What matters is what the promisor's words and conduct would convey to a reasonable promisee, not the promisor's private state of mind.
Lucy v. Zehmer operationalizes the objective theory: Zehmer's secret jest does not unmake the manifestation of commitment a reasonable Lucy would receive.
Common misunderstanding: students collapse promise into intent. The doctrine asks what the recipient was justified in understanding, not what the speaker secretly meant. Aspiration, prediction, and puff fail because they do not justify a reasonable promisee in understanding that a commitment has been made.
Cases that operationalize this rule
Subsection (1) makes clear that a promise is defined by manifested commitment, not by private state of mind. The language “so made as to justify” foregrounds the objective theory that runs throughout formation doctrine. In teaching and litigation alike, the section is often paired with cases examining whether language is promissory or merely aspirational.