The North Carolina Court of Appeals, absent a state civil damages act, has found commercial vendor liability by deriving duty from the violation of a criminal statute.
Hutchens v. Hankins, 303 S.E.2d 584 (N.C. Ct. App.), review denied, 309 N.C. 191, 305 S.E.2d 734 (1983).
Madelyn A. Reilly,
Tort Law - Liability of Commercial Vendor of Alcohol - Duty Derived from Violation of Criminal Statute,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol22/iss4/16