On January 27, 2002, Michael Enders was driving in the District of Columbia, and became involved in a traffic incident/altercation with Kathleen Cravedi. Specifically, Mr. Enders was aggravated by Ms. Cravedi's vehicle being parked in the street, well off the curb. He pulled up beside her to ask about her vehicle's location, but she quickly dismissed him and returned to her cell phone. While the facts are in dispute as to the purpose, and force, there is no question that Mr. Enders then arranged his vehicle behind Ms. Cravedi's car, and struck it with his own. Then, Mr. Enders drove away to his home, which was located nearby, while Ms. Cravedi got the attention of the police. Officer Davis of the Metropolitan Police Department located Mr. Enders quickly and asked him to return to the scene.

After conducting investigation and interviews at the scene, the police arrested Mr. Enders without an arrest warrant. As a result, Mr. Enders filed suit against the District of Columbia alleging false arrest. The District of Columbia obtained a defense verdict at the jury trial. However, Mr. Enders contended that the trial court's jury instructions were in error, specifically in that they directed that the Plaintiff could not prevail on a claim of false arrest as long as the police had probable cause that Mr. Enders had committed any crime.

The essential elements of a claim of false arrest are: (1) a detention or restraint against one's will, and (2) the unlawfulness of such a detention. The key element in this case then was to determine if the arrest was in fact unlawful. The Court of Appeals noted that at common law, an officer could make a warrant-less arrest only if a person was attempting to commit a felony or breaching the peace in front of the officer. But the District of Columbia has enacted D.C. Code § 23-581(a)(1), which substantially expanded an officer's authority to make an arrest without a warrant.

Despite this expansion, a police officer's probable cause that a misdemeanor was committed is insufficient for the most part, as only certain enumerated misdemeanors will suffice. The Court of Appeals noted that it is important not to confuse the state law regarding appropriate warrant-less arrests, with the constitutional standard for probable cause. Specifically the Court stated that limiting the showing to only meeting the constitutional probable cause standard would essentially make the statutory language null and void.

Therefore, the jury instructions providing that the District of Columbia only needed to show probable cause for any arrest, was improper and prejudicial. On remand, the District must show that there was probable cause to make an arrest for at least one crime that comes under the statute (including intentionally inflicting property damage over $200).

Finally, the District of Columbia also argued that even if the jury instructions were improper, Mr. Enders' Complaint should have been dismissed for failure to comply with the notice provisions for filing suit against the District of Columbia. While Mr. Enders issued correspondence to the District within the relevant time frame, the District contended that the letter did not state the place of the injury, or the underlying circumstances. The Court held that since a police report for the incident was also created, and could be read together with the letter to provide all information required under the Statute, the District of Columbia could not reasonably argue it did not have sufficient notice of the claim.