What is a memorandum of understanding and when does it become an agreement?

A memorandum of understanding (MOU) is a writing that records what parties understand about a proposed arrangement. Under Washington law, it becomes an enforceable agreement when the parties objectively manifest assent to sufficiently definite terms and exchange consideration; calling it an “MOU” does not decide the question.[2]

What distinguishes an agreement from a negotiating memo?

What the MOU showsLikely effect under Washington law
The parties intend to be bound now to definite terms, with considerationIt may be an enforceable contract, even if a more formal document will follow.[2][1]
The parties leave a material term for future agreement, without an agreed way to resolve itIt is generally an unenforceable “agreement to agree.”[2]
The writing says the parties will negotiate or prepare an agreement for later review and executionThat may indicate no present intent to be bound. A separate promise to follow specified negotiating procedures would require its own formation analysis; Washington’s Supreme Court has not decided whether such a contract to negotiate is independently enforceable.[2]

A later signature is not always the dividing line. An informal writing can establish a contract despite plans for a formal document. Washington courts examine whether the subject matter and terms were agreed upon and whether the parties intended to be bound before signing the later document.[1] Conversely, a response that conditions acceptance on a material change is ordinarily a counteroffer, not acceptance.[3]

Practical test: Read the MOU and the parties’ outward conduct as a whole. Did they commit to an identifiable bargain now, or merely record progress toward one? Washington uses objective manifestations, not an undisclosed intention or the document’s title, to answer that question.[2]

Sources & References

  1. In re the Marriage of Green (Wash. Ct. App. 2020)
  2. Keystone Land & Dev. Co. v. Xerox Corp., 152 Wn.2d 171 (2004)
  3. Sea-Van Inv. Assocs. v. Hamilton, 125 Wn.2d 120

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