Garratt v. Dailey
What Happened: Garrat alleged that Dailey, a five year-old boy, moved a chair away just as she was about to sit down in it, causing her to fall and to be injured.
Question Before the Court: Intent necessary to establish Battery.
Court Ruling: The Court held that battery could only be found if it is shown that the boy knew with "substantial certainty" that by moving the chair Garratt would attempt to sit in the chair's original position. That is, the accused must be substantially certain that his action would cause the offensive contact. The absence of an intent to injure or play a joke is not sufficient to absolve the accused of liability. It is sufficient for the plaintiff only to prove that the accused had sufficient knowledge to foresee the contact with "substantial certainty".