Tort actually refers to the part of the law that permits remedies for people who have been wronged outside of contractual or criminal wrong doing.

The tort issue here is not related to the fisticuffs but, rather, whatever damage was caused to the victim. The damage could be "direct" such as plastic surgery, maxilofacial surgery or dental/orthodontic work required to return the victim's face back to the way it was before she was struck. It can also be "indirect", such as lost wages while recovering from the injury or treatment from the injury. There are other kinds of damages and other sources of potential tortfeasance in situations like this.

That's why people often say that it's better to kill your assailant than send him to the hospital. Of course, now, even that's a real problem because you can be sued by the surviving family for wrongful death. That's what Joe Horn has to tackle next. That's what destroyed OJ's life after he won in criminal court (the standard for conviction in a criminal case is much higher than the standard to prevail in a civil case).