In Fall River Joint Unified School Dist. v. Superior Court (1988) 206 Cal. App. 3d 431, the claim stated the accident was caused by a defective door that closed with excessive force. The subsequent complaint premised the right to recover on the school's negligent failure to supervise students engaged in "dangerous horse-play." ( Id. at p. 434.) The Court found the attempt to premise liability on an entirely different factual basis than that set forth in the tort claim was a fatal variance. ( Id. at p. 435.)