Making Sense of Battery: Intent to Contact vs. Intent to Harm

I keep getting tripped up on this point and could use some clarity.

In single intent jurisdictions, battery only requires the intent to make contact (purposeful or with substantial certainty). The actor doesn’t need to intend harm, and not fully understanding the consequences isn’t a defense. Once intent to contact is shown, the contact is judged objectively: was it harmful or reasonably offensive? If yes, that’s battery.

But here’s my confusion: the Restatement (Second) of Torts says battery happens when someone “intended to cause a harmful or offensive contact.” To me, that sounds like intent to harm (or offend) is required. Yet courts interpret this under single intent as just “intent to contact.”

So which is it? Is the Restatement’s wording really just shorthand for intent to contact, with harmfulness/offensiveness measured objectively afterward? Or is this one of those places where judicial gloss has effectively reshaped the language?

Would love to hear how you all make sense of this. Have you seen bar exam questions or hypos that really tested this distinction?

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