Cited by

Appeal of Sanborn Regional School Bd., 133 N.H. 513, 520-22 (1990); see also RSA 273-A:1, VII (2010) (amended 2014) (defining “[l]egislative body” as “that governmental body having the power to appropriate public money”).

The parties to a CBA are not bound by its cost items unless the legislative body ratifies them, which occurs only if the legislative body approves them with “full knowledge of their terms.” Alton School Dist., 140 N.H. at 307 (quotation omitted); see also Appeal of Sanborn Regional School Bd., 133 N.H. 513, 520 (1990) (“[W]hether express or implied, ratification.

“Ratification by a municipal corporation can be express or implied.” Appeal of Sanborn Regional School Bd., 133 N.H. 513, 520 (1990).

We treat the PELRB’s findings of fact as prima facie lawful and reasonable, and its order prevails “in the absence of a clear showing of unreasonableness or illegality.” Appeal of Sanborn Regional School Bd., 133 N.H. 513, 521, 579 A.2d 282, 286 (1990); see RSA 541:13 (1997).

Although the board argues that there was no meeting of the minds relative to the July 1994 lump sum payment, arguably a material provision of the contract, cf. Appeal of Sanborn Regional School Bd., 133 N.H. 513, 518, 579 A.2d 282, 284 (1990) (for an enforceable CBA to be formed a meeting of the minds as to its terms is required), it nonetheless asks this court to enforce the agreement “legally in effect” between the parties.

Among the requirements for contract formation is a meeting of the minds about terms — “each party must have the same understanding as to the terms of the agreement.” Appeal of Sanborn Regional School Bd., 133 N.H. 513, 518, 579 A.2d 282, 284 (1990).

“In order for a contract to be formed there must be a meeting of the minds as to the terms thereof.” Appeal of Sanborn Regional School Bd., 133 N.H. 513, 518, 579 A.2d 282, 284 (1990).

Appeal of Sanborn Regional School Bd., 133 N.H. 513, 520, 579 A.2d 282, 285 (1990).

Our decision in Appeal of Sanborn Regional School Board, 133 N.H. 513, 579 A.2d 282 (1990), requires cost items like the accumulated sick leave buyback provision to be approved by the local legislative body.

Appeal of Sanborn Regional School Bd., 133 N.H. 513, 521, 579 A.2d 282, 286 (1990); RSA 541:13.

Appeal of Sanborn Regional School Bd., 133 N.H. 513, 519-20, 579 A.2d 282, 285 (1990).

Our decisions interpreting RSA chapter 273-A bolster our construction of the phrase “whose implementation requires an appropriation.” For example, we held in Appeal of Sanborn Regional School Bd., 133 N.H. 513, 520-22, 579 A.2d 282, 286-87 (1990), that a local legislative body may not be bound by a CBA without first being fully informed of the details of its financial terms.

This reasoning is also con *243 sistent with our decision in Newfound Area Teachers Asso ciation (Decision No. 91-109, December 16, 1991) after the Sanborn decision (133 N.H. 513, [ 579 A.2d 282 ] August 14, 1990) where we again noted that ‘the existing agreement did not contain an automatic renewal clause which would have given all of the teachers an automatic “step raise.’T] Thus, our analysis, both before and after Sanborn, leads us to conclude that there is entitlement to step increases u

Under Appeal of Sanborn Regional School Bd., 133 N.H. 513, 579 A.2d 282 (1990), the association contends, implied ratification of the CBA’s first year cost items constitutes ratification of the CBA’s second and third year cost items.