Can a five-year-old child be held legally liable for battery against an adult?

On July 16, 1951, an incident occurred in the backyard of Ruth Garratt's home involving Ruth Garratt, an adult, and Brian Dailey, a five-year-old boy. Ruth Garratt alleged that Brian Dailey pulled a chair out from under her as she was about to sit down, causing her to fall and sustain injuries, including a fractured hip. Brian Dailey's account differed, claiming he had moved the chair but attempted to replace it when he saw Ruth about to sit, yet was unable to do so in time due to his small size and lack of dexterity.

The trial court found that Brian Dailey did not have any willful or unlawful purpose, intent to injure, or intent to bring about unauthorized contact. The court determined that Brian had moved the chair and then attempted to move it back to aid Ruth in sitting down. Ruth Garratt's injuries were assessed at $11,000 in damages. The case also involved Naomi Garratt, Ruth's sister, as another party, though her specific role was not detailed in the provided information.

Ruth Garratt initially brought an action against Brian Dailey in a lower court. The lower court dismissed the action against Dailey. Dissatisfied with this outcome, Garratt appealed the dismissal to the Supreme Court of Washington. In her appeal, Garratt requested either the entry of an $11,000 judgment in her favor or a new trial.

(Hill, J.)

Yes. A five-year-old child can be held legally liable for battery against an adult. The intentional infliction of harmful bodily contact upon another constitutes battery, regardless of the age of the perpetrator. The key element is the intent or knowledge of the actor, not their age. For battery to occur, the act must be done with the intention of bringing about harmful contact or with knowledge that such contact is substantially certain to be produced. A child's age is only relevant in determining what they knew or could reasonably foresee, not in exempting them from liability altogether. The standard applied is whether the child knew with substantial certainty that the harmful contact would occur as a result of their actions. In cases involving young children, the court must carefully examine the child's understanding and awareness of the consequences of their actions. The child's mental state, comprehension of cause and effect, and ability to foresee potential harm are crucial factors in determining liability. While a child may not fully grasp complex legal concepts, they can still be held accountable if they understood that their actions would likely result in harmful contact. This principle ensures that victims of intentional harmful acts are not left without recourse simply because the perpetrator is a minor. However, the application of this standard requires meticulous fact-finding and analysis of the specific circumstances surrounding the incident. Courts must make definite findings on whether the child knew with substantial certainty that their actions would result in harmful contact. If such knowledge or intent is established, the child can be held liable for battery, regardless of their age.