Battery is the tort of a defendant acting with the intention to cause a harmful or offensive contact with the plaintiff, and then causing such harmful or offensive contact. It's usually a pretty straightforward example of a tort. The terminology can be a little confusing because we also have the tort of assault, which is where a defendant acts with the intent to cause a apprehension of contact that's harmful or offensive. And the terminology there is confusing because in the criminal law, the state can prosecute people for assault or aggravated assault, as it would be. And those kinds of conduct, that kind of conduct, is often what we in torts would call battery. So it's helpful to kind of keep the terminology of battery and assault clearly in mind when we're talking about the torts context as opposed to when you might encounter it in the criminal law context. An assault is where a defendant acts with the intention of causing an apprehension in a plaintiff of imminent, harmful, or offensive contact, and does in fact cause such apprehension. So an example that a lot of case books use, for example, is that if a defendant points a gun at a plaintiff that is an assault because it creates an apprehension of imminent, harmful, or offensive contact. And then if someone fires the gun at someone, that's a battery, because then you've not only caused apprehension of imminent, harmful, or offensive contact, but you've in fact caused harmful or offensive contact. On the other hand, if someone comes from behind somebody and just grabs their shoulders and shakes them, there's not been an assault because there was no apprehension. But there is a battery, because the person has been touched in a manner that is potentially harmful or offensive. There are cases involving things like a smoker, for example, on a talk show who was blowing smoke at an anti-smoking advocate in which the court held that that was sufficiently contact to constitute a battery; a famous case involving grabbing a tray rom someone at a buffet, and pushing it out of their hands. And in that case, the court held that the tray was an extension of the person, and to that extent could be sufficient for the contact of battery, but usually we're talking about things like a punch in the face, or other kinds of physical contact.