White v. Muniz

White's (defendant) elderly grandmother Everly, who showed dementia-related aggression, struck her caregiver Muniz (plaintiff) while being changed. Muniz sued Everly and White for battery; the trial court instructed the jury it could find Everly liable only if she intended both to strike Muniz and to make the contact offensive, and the jury found neither Everly nor White liable. The court of appeals reversed, holding the instruction erroneous, and White appealed.

Whether, to be liable for battery, a person must intend both to cause contact with another and intend that the contact be harmful or offensive.