Local 336, International Brotherhood of Electrical Workers, Afl-Cio v. Detorrice

Plaintiff, Local No. 336, International Brotherhood of Electrical Workers (IBEW), AFL-CIO, filed separate small claims complaints against defendants, Patricia Detorrice and Christopher Sabathne, claiming an indebtedness of $1,018.40 and $451, respectively, for assessments levied against each defendant as members of the union. Each defendant moved for summary judgment, and the trial court granted each motion. As the same issues are presented by the parties, the cases were consolidated by this court on appeal.

Plaintiff raises the following issues for review: (1) whether the procedure used to…