Two men, Johnny Walker and Joe Coors were leaving a bar after some drinking and got into an argument. Johnny was carrying a briefcase and as the argument got heated Johnny swung the briefcase at Joe causing Joe to step back to avoid the briefcase. In stepping back, he tripped over a low fence, injuring himself.

What civil action in intentional tort can Joe take against Johnny? Under intentional torts, what, if any, could be Johnny's defense?