Can a Home-Rule Unit Exercise Its Authority Without a Majority Vote of the City Counsel ?

In City of Burbank v. Illinois State Labor Relations Board, 185 Ill. App. 3d 997, 541 N.E.2d 1259, 133 Ill. Dec. 821 (1989), a city attorney entered into a final settlement agreement with a union. See City of Burbank, 185 Ill. App. 3d at 1000, 541 N.E.2d at 1262. The city argued that it was not bound by the terms of the settlement agreement because the agreement was not approved by a majority vote of the city council as required by the Code. See City of Burbank, 185 Ill. App. 3d at 1004, 541 N.E.2d at 1264. The court held that a city may exercise its home-rule authority by approving a settlement agreement without a majority vote of the city council making a prior appropriation for the contract. See City of Burbank, 185 Ill. App. 3d at 1005, 541 N.E.2d at 1265. City of Burbank clearly holds that a home-rule unit can exercise its authority without a majority vote of the city council. See City of Burbank, 185 Ill. App. 3d at 1005, 541 N.E.2d at 1265.