TERRY, Associate Judge:
Elijah Karriem, a street vendor in the District of Columbia, was arrested on three occasions in 1988 and 1989 for failing to obey police orders to relocate his vending stand and for vending in an entrance zone. After each set of charges was dismissed, Karriem sued the District and several individual police officers, alleging false arrest, defamation, and various other intentional torts.
The three cases against the District were consolidated...
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