In 1993, the United Arab Emirates ("UAE") held a competition to select the architectural design of its new embassy to be built in Washington, D.C. Elena Sturdza, an architect licensed in Texas and Maryland, but not the District of Columbia, entered a design and won the competition. Thereafter, Ms. Sturdza and UAE exchanged several counter proposals and worked together to modify Ms. Sturdza's design for UAE's purposes over the course of several years. However, UAE ultimately did not sign a contract with her, and instead retained architect Angelos Demetriou.

Mr. Demetriou, a D.C. licensed architect, had also entered a design in the original competition. However, his design eventually used by UAE appeared to incorporate and appropriate features from Ms. Sturdza's design, and ones that his original submission did not contain. Ms. Sturdza filed an action in the U.S. District Court for the District of Columbia against UAE and Mr. Demetriou. Included in her Complaint were alleged claims of breach of contract and quantum meruit against UAE. She argued that to a large degree, she had substantially performed her obligations with regard to the design of the embassy. On appeal, the Court of Appeals for the District of Columbia determined the question regarding D.C.'s licensing procedures and its potential bar to recovery was best left to the D.C. court systems as it raised a question of extreme public importance.

The District of Columbia has a licensure requirement on the practice of architecture in the District of Columbia. D.C. Code §47-2853.63 (2001). In order to safeguard life, health, property, and to promote the public welfare, no person may engage in the practice of architecture in D.C. without being licensed. The practice of architecture is defined to include both rendering and "offering to render" services in connection with the design and construction of a structure. It includes planning and providing technical submissions. Therefore, the Court determined that the practice of architecture under the statutory structure encompasses not just performance of architectural services, but also negotiating agreements to perform those services.

The Court was convinced that despite Ms. Sturdza's licenses in other jurisdictions, she was not permitted to practice architecture in D.C.—even in light of the international design competition. As the Plaintiff was not a licensed architect at the time she engaged in negotiations with UAE, and substantially performed certain design work, she was barred from recovery in a contract or quasi-contract action. The Court noted that while the result can be harsh, it is the well-established law of the District of Columbia that a contract made in violation of a licensing statute will be considered void and unenforceable. The Court noted that it has uniformly rejected appeals to deviate from this hard and fast rule, and was not inclined to do so here.