In Slaughter v. Slaughter, 264 N.C. 732, 736, 142 S.E.2d 683, 686-87 (1965), the Supreme Court of North Carolina upheld a jury verdict that a man was negligent for setting off firecrackers by the window of his elderly mother with the express intention of frightening children in his mother's care. He intended his actions as a practical joke, but his mother heard the firecrackers as gunshots and fell to the ground attempting to avoid them, thereby breaking her hip. Id. at 734, 736, 142 S.E.2d at 685, 687. There was no question of contributory negligence by the mother.