an unlawful battery, or that it would result in bodily harm. Dorn did, however, intentionally apply force to another person, which satisfied the mens rea element of assault-harm, B. Next, We consider whether Dorn’s conduct constituted a battery, and therefore satisfied the actus reus required for assault-harm. The court of appeals determined that Dorn’s conduct constituted a battery because she applied physical force to D.E. Dorn, 875 N.W.2d at 361-63. In Minnesota, the separate crime of battery has been incorporated into the definition of assault. Compare Gallagher v. State, 3 Minn. 270, 271-73, 3 Gil. 185, 187-88 (1859) (discussing the common-law crime of “assault and battery,” which included striking another person), with State v. Basting, 572 N.W.2d 281, 286 (Minn. 1997) (<HOLDING>). At common law, criminal battery was “the
holding that simple assault includes urinating on another holding that an assault and battery is an unlawful and unjustifiable use of force and violence however slight upon the person of another holding that punching another person is a statutory assault holding simple assault is a lesser included offense of recklessly endangering another person holding that a threat to harm another person is a crime of violence