In Carter v. Carlson, 144 U.S.App.D.C. 388, 447 F.2d 358 (1971), a policeman was sued for making an arrest without probable cause. The District of Columbia Court of Appeals concluded that the officer was not subject to suit if he was performing a "discretionary" rather than "ministerial" function. The Court noted that the exercise of "discretion" by the officer in the sense of choosing among alternative courses of action does not automatically trigger official immunity: The proper approach is to consider the precise function at issue, and to determine whether an officer is likely to be unduly inhibited in the performance of that function by the threat of liability for tortious conduct. 447 F.2d at 362. In Carter v. Carlson, 144 U.S.App.D.C. 388, 447 F.2d 358 (1971), subsequently reversed on other grounds in District of Columbia v. Carter, 409 U.S. 418, 93 S.Ct. 602, 34 L.Ed.2d 613 (1973), it was held that a complaint which alleged that the plaintiff was arrested without probable cause and beaten with brass knuckles by one Carlson, a policeman, sufficiently alleged a cause of action against the policeman under 1983. In so holding, the Court said at page 363: 'An arrest without probable cause, or an arrest made with excessive force, constitutes an unreasonable seizure in violation of the Fourth Amendment.'