Rhodes had escaped but was followed by "a car driven at speed towards you - driven allegedly by a Mongrel Mob member".
"You jumped out of the way and the car hit Mrs (Quanita) Robinson, who is in court today," the judge said.
Mrs Robinson was in court, seated in a wheelchair and accompanied by other family members.
Judge Hastings said Rhodes had given chase and "mistakenly hit and kicked the person you thought was the driver".
On April 30 many were due to appear in Masterton District Court in connection with the altercation, the judge said.
"Members of both factions faced off apparently across the street in the parking lot."
Rhodes' lawyer, James Elliot, said the victim of Rhodes assault here had been the aggressor, approaching Rhodes and an associate "with a hammer and what appears to be a large lug wrench".
Mr Elliot said the man was "very clearly advancing", but was shown by cameras to retreat as police approached.
Rhodes was "17 and full of adrenaline having been attacked with a weapon", Mr Elliot said, and he claimed what followed was "excessive self defence".
Judge Hastings was not sure, saying that the weapons were being hid in a car at the time of the assault.
Rhodes had punched the man in the face and knocked him to the ground; he was knocked unconscious and broke his hand, and Rhodes had then kicked him while he was on the ground.
James Elliot said gangs were involved, but the problem was not that "as much as conflict and trouble between two extended families".
Mr Elliot said there was later a "meeting, or hui if you like, between senior members of the families".
Some involved had "been telling me there has been no violence since these occasions".
Judge Bill Hastings replied, "that can only be a good thing".
