When can words alone be sufficient for establishing an assault claim?

Words alone can support an assault claim when they are combined with acts that create anticipation of imminent harmful or offensive contact. This means that the context in which the words are used is critical; they must convey a clear and immediate threat that leads the victim to reasonably anticipate that harm is about to occur. It is the combination of threatening words with accompanying behavior—such as raising a fist, advancing towards someone in a menacing manner, or any action that conveys intent—that establishes the necessary apprehension of imminent contact.

The reasoning hinges on the requirement for a plaintiff to demonstrate that they had a reasonable fear of imminent harm. Assertions that lack clarity or are vague do not suffice to instill such fear. Context is crucial in interpreting whether the words, when joined with actions, effectively convey a threat that could cause apprehension in a reasonable person. Thus, the combination of words and actions plays a vital role in forming an assault claim under tort law.