Battery is an offensive touching

http://coa.courts.mi.gov/documents/OPINIONS/FINAL/COA/20100126_C287416_44_287416.OPN.PDF

In People v. Federoff, the Michigan Court of Appeals discusses the elements of Michigan's assault and battery statute, MCL 750.81.  Relevant to immigration practicioners, this statute can be violated through offensive touching that is not forceful or violent.  A domestic violence offense can be committed even if the defendant intended to assault and batter another individual but mistakenly or accidentally assaulted or battered a protected person.