In Clausing v. San Francisco Unified School Dist. (1990) 221 Cal.App.3d 1224, the court determined a California Constitutional provision declaring that all students "'have the inalienable right to attend campuses which are safe, secure and peaceful'" imposed no affirmative duty on the part of school districts, provided no remedy for its violation and created no private right of action. (Id. at p. 1236.) Characterizing the safe schools provision as "closely analogous" to article I, section 1 of the California Constitution, the court reasoned: "Clearly, although safety and happiness are inalienable rights, this provision article I, section 1 of the Constitution does not establish the means whereby they may be enjoyed. No case has ever held that this provision enunciating the inalienable right to obtain safety and happiness is self-executing in the sense that it gives rise, in and of itself, to a private right of action for damages or an affirmative duty on the part of the state to take particular steps to guarantee the enjoyment of safety or happiness by all citizens. " (Clausing v. San Francisco Unified School Dist., supra, at p. 1237, fn. 6.)