Joe was jogging along a deserted trail beside a river when he met Sam coming the other way. Joe stopped and, in conversation with Sam, accused Sam of stealing and shoplifting from the store. Sam was appalled, became irate, and struck Joe in the nose. In the resulting fight, Joe was injured, suffering a broken nose and significant bruises. Finally, after some time, another jogger came along the trail and broke up the fight. Joe sued Sam for battery and Sam sued Joe for defamation. Explain the likely outcome.