Sam had just finished a great day of skiing as he walked toward the parking lot with his skis over his shoulders. While waiting to cross at a crosswalk, a car's horn honks down the street. He suddenly turns to see where the sound came from, and in doing so his skis swing around and hit Pam in the head, injuring her. Which of the following, if true, would give Sam the best chance of avoiding liability to Pam?
a. Sam did not intend to harm anyone when he turned to see the source of the sound.
b. The driver of the car violated an anti-noise ordinance in blowing the horn.
c. Pam had planned to cross the crosswalk as soon as traffic allowed, rather than wait for the "walk" light to indicate that it was safe to do so.
d. Pam had been walking behind Sam for several hundred yards and had observed that Sam, on several occasions, had nearly struck other persons as he carried his skis.