Small Claims Action

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WI Court of Appeals – District III

Case Name: ABase Storage LLC v. Michael Michaud

Case No.: 2021AP001563

Officials: Stark, P.J.

Focus: Small Claims Action

ABase Storage rented a storage unit to Michaud on August 20, 2018, pursuant to a written lease that allowed Michaud to store thirty-five vehicles at a monthly rent of $1,000. Michaud failed to make the payments required by the lease, and ABase Storage commenced this small claims action against him. A

bench trial was held on June 17, 2020. The circuit court issued an oral ruling in favor of ABase Storage on May 24, 2021. It entered a written judgment awarding ABase Storage $28,091.63 on September 1, 2021. Michael Michaud, pro se, appeals a judgment entered in favor of ABase Storage LLC. Michaud argues that: (1) ABase Storage violated WIS. STAT. § 757.30 by filing documents in this case without a lawyer. Wisconsin Statutes explicitly authorizes a corporate entity to self-represent in a small claims action by a full-time employee who is not a lawyer. (2) this action should have been dismissed under 50 U.S.C. § 3931, a federal statute that provides protection to military service members against the entry of default judgments without notice.  50 U.S.C. § 3931 is not applicable in this matter (3) the circuit court failed to address the issue of ABase Storage’s warehouse lien;  Michaud is not entitled to relief based on a claim related to the warehouse lien. (4) The court failed to explain why the Wisconsin consumer act, WIS. STAT. chs. 421 to 427, does not apply to this action. Michaud fails to explain why he believes the court’s ruling was incorrect; he simply states that the court did not provide a sufficiently thorough explanation; and (5) the court engaged in judicial misconduct.

Affirmed.

Decided 09/06/23

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