A weak E layer in a non-uniform magnetic field will tend to precess as a rigid body in response to the radial focusing of external magnetic fields and fields due to wall currents. We study the interaction of this precessional mode with a background plasma, and we explicitly include dissipation mechanisms in the plasma, walls and external resistors. When the plasma background is treated in the MHD approximation, we find that the mode changes character from a precessional mode at low density to a compressional Alfvén wave at high density. For a very weak E layer, instability is found, even without dissipation, when a sufficiently high background plasma density is present. However, for moderate E-layer strengths, the modes are found to be stable, even with dissipation.