Obviously, there are many different ways in which the “holding” of this case might be accurately stated. The important point to emphasize here, as with re-stating the “holding” of almost all judicial opinions, is that the “holding” must include certain “key” legal terms or concepts that accurately reflect HOW the court has responded to the specific legal issue(s) that were presented to it. Thus, there is not necessarily any one particular way of articulating or phrasing the “holding” that is “right,” but there are many incorrect ways of doing this.
For example, BOTH of the following statements of the court’s “holding” in the Garratt case are at least technically correct, because they each contain and properly address most of the key legal elements of the court’s analysis in this case:
Alternative (A): Liability for a “battery" can be established even absent proof that Defendant had any [i.e. actual] intent to cause harmful (or offensive) contact with the Plaintiff's person?
Alternative (B): Even absent proof that Defendant had any [actual] intent to cause harmful (or offensive) contact with the Plaintiff's person, liability for a “battery” can also be established where the Defendant is shown to have acted with knowledge to a substantial certainty that [harmful or offensive bodily] contact to the Plaintiff’s person will occur.
While either of these two alternative versions, supra, of the holding in the Garratt case may be at least technically “correct” (as well as perhaps any number of other versions that use similar phraseology), alternative (B), supra, is probably the better choice to use in your brief, since it provides two additional things that alternative A does not.
(1). First, the alternative (B) version of the “holding” is a more accurate statement of what the Garratt court actually held, since it also explains HOW the requisite intent for the tort of “battery” can be proven when there is no proof of the defendant’s “actual” intent. Notice that the alternative (A) version of the “holding,” supra, stops short of this by merely stating (or implying) that there IS some other way (or ways) that the requisite “intent” for the tort of “battery” can be proven, but it doesn’t state what those ways might be.
(2). Alternative (B) of the court’s “holding,” supra, also specifically incorporates the actual language that is used by the Garratt court in articulating the legal test that it used to explain its reasoning for recognizing ONE additional KIND of “intent” that is sufficient to support a claim for the tort of “battery.” This specific language became incorporated into the generally accepted definition of what we now refer to as the concept of “implied” intent. By incorporating this additional language into your statement of the Garratt court’s “holding,” the actual legal “rule” that can be derived from this “holding” statement is much more useful when citing the Garratt case as precedent in future cases.