Radio emission from dMe flare stars has both a flaring and a quiescent component. When we compare stellar radio emission with the Sun, however, we find that the apparent brightness temperature of the quiescent component often exceeds the temperature of non-thermal solar radio flares, and so it is likely that stellar quiescent emission also comes from non-thermal electrons. The duration of stellar quiescent emission is much longer than solar non-thermal emission. Obvious questions to ask are, what is the source of the non-thermal electrons, where do they reside, and how can non-thermal emission last so long? Here we briefly review the observations of quiescent emission, argue that the emitting regions are small, show that such small regions can still account for the observed fluxes, and discuss the source of electrons.