46 Wn.2d 197, 279 P.2d 1091 (Wash. 1955)
Garratt v. Dailey is a foundational torts case that crystallizes the meaning of "intent" in the intentional tort of battery.
Does the intent element of battery require a purpose to cause harm, or is it satisfied if the defendant knew with substantial certainty that the plaintiff would experience a harmful or offensive contact as a result of the defendant's act, and can a young child possess such intent?
For battery, an actor is liable if he acts intending to cause a harmful or offensive contact with another (or an imminent apprehension of such contact), and a harmful or offensive contact directly or indirectly results. Intent is satisfied by either (1) the purpose to cause the contact or (2) knowledge to a substantial certainty that such contact will occur. A defendant's youth does not preclude forming the requisite intent for an intentional tort. See Restatement (First) of Torts §§ 13, 16.
Intent for battery includes knowledge to a substantial certainty that harmful or offensive contact will occur, and a minor can possess such intent. Because the trial court did not determine whether Dailey knew with substantial certainty that Garratt would attempt to sit and fall when he moved the chair, the case was remanded for findings on that question.
Garratt v. Dailey is central to understanding the intent requirement in intentional torts. It cements the substantial-certainty test, distinguishing intent from negligence and recklessness, and illustrates that liability for battery turns on the actor's mental state regarding contact, not on a desire to injure. The case also teaches that minors can be liable for intentional torts if they possess the requisite intent, making it a frequent vehicle for exam hypotheticals about child defendants, indirect contact, and the boundary between intentional and negligent conduct.