I had the same error pop up Saturday night, Dec 23 around 10:00-30pm after going to pick up my car at service. I found the car and was able to drive it from their back lot to the front of the service center with no issues, so I can transfer my things from my loaner to my car. After I did all that, I got back in the car and saw the error there waiting for me when I put it into D. I did 2 resets (held the 2 buttons on the steering wheel), and still nothing. I stepped out and made calls to any Tesla cuistomer support that time at night but no help. I came back in the car and the message disappeared. I was able to drive up and down the road, making 2 U turns with no issues at all.
Leads me to believe it isn't an issue with the hardware, like motor etc... since it works again. Might be some weird sensor issue. My car was sitting at their lot for the whole day as well. They had changed the aft links due to squeaking. Not sure if that is even related. Or maybe low voltage on the v12 battery?
I left my car there because I was not confident to take it back home on a 45 minute drive. I kept the loaner and still waiting for them to look at it. Hope it is nothing because already threw money at the car for other repairs.