Feel free to look up some legal definitions sometime, guys. There's whole law libraries sitting online for the purpose of reference. It's not a question of damage, it's the action itself. [quote=Findlaw]The criminal act required for battery boils down to an offensive or harmful contact. This can range anywhere from the obvious battery where a physical attack such as a punch or kick is involved, to even minimal contact in some cases. Generally, a victim doesn't need to be injured or harmed for a battery to have occurred, so long as an offensive contact is involved. In a classic example, spitting on an individual doesn't physically injure them, but it nonetheless can constitute offensive contact sufficient for a battery. [/quote] And no, CNN reporters do not constitute hostile entities. If you think otherwise, well, I hope you never need your rights in the face of law enforcement. The guy was obeying orders even without being shoved; he was stating that he would not resist and that he would comply. That's not precisely hostile or uncooperative, despite whatever your definition of hostility is.