Kisses and Laser Beams: How Slight is a Battery in Virginia?

Pretty slight:

"The slightest touching of another if done in a rude, insolent, or angry manner, constitutes a battery." Kelley v. Commonwealth, 69 Va.App. 617 (2019)(unwanted kiss is a battery). This slight touching does not necessitate physical contact between the two individuals. See Hardy v. Commonwealth, 58 Va. 592, 601 (1867)(Spitting), Adams v. Commonwealth, 33 Va. App. 463 (2000)(laser beam), Gilbert v. Commonwealth, 45 Va.App. 67 (2005 (spitting), & Moore v. Commonwealth, Va.App. no. 0721-17-2 (2018 (U)(spitting). "In Virginia, it is abundantly clear that a perpetrator need not inflict a physical injury to commit a battery." Adams v. Commonwealth, 33 Va. App. 463 (2000). “It is sufficient if it does injury to the victim's mind or feelings.” Kelley.

(Lifted from a brief I wrote a year back or so.)