District of Columbia Court of Appeals, 1980

The court affirmed summary judgment for the District and the individual defendants on all claims arising from the mistaken arrest. It held that the defendants could assert defensive issue preclusion despite not having pleaded it, and that findings in the Jacksons’ prior federal action barred several claims; the…

The court affirmed dismissal of the widow’s claims, concluding that the alleged conduct did not support an inference that the defendants intended or recklessly caused severe emotional distress with a foreseeable risk of physical injury.