Trespass to the person in United States

Trespass to the person 

Trespass vi-et-armis also known as trespass force and arms is an archaic form for a claim of battery. It was concurrent form of action to trespass on the case but possibly only because the common law did not allow pleading in the alternative under the writ system. As code pleading permits pleading in the alternative this tort may have merged into that of battery. The distinction turned on pleading forms which have been abandoned for over a century and yet which subsist at least in theory.

Mawson v. Vess Beverage Co., Mo.App., 173 S.W.2d 606, 613.