In Avila v. Citrus Community College District (2006) 38 Cal.4th 148, the California Supreme Court enunciated the primary assumption of risk doctrine. In that case, the plaintiff was struck in the head with a pitch during an intercollegiate baseball game. The plaintiff alleged that the pitcher, who played for the home team, had intentionally thrown the ball toward his head. The plaintiff filed a negligence complaint alleging that the host school had failed to provide visiting opponents with proper medical care and failed to supervise and control its student-athlete. The college demurred, contending it had no duty of care to protect the plaintiff from the perpetrator's intentional, wrongful conduct. In its analysis, the Supreme Court explained that prior decisions had established elementary and secondary schools "have a duty to supervise students , a duty that extends to athletic practice and play ." (Avila, supra, 38 Cal.4th at p. 158.) The Court noted that "colleges and universities do not owe similarly broad duties of supervision to all their students " (ibid.), but explained that a "separate body of law had developed" (id. at p. 159) recognizing that "colleges and universities owe special duties to their athletes when conducting athletic practices and games" (id. at p. 158). The court found it reasonable to extend this duty to visiting athletes, concluding that the "benefits" a host school derives from "intercollegiate competition" (including economic benefits) justified imposing a "duty to home and visiting players alike to ... not increase the risks inherent in the sport." (Id. at p. 162.) The court clarified it had "no quarrel" with prior cases holding that colleges "owe no general duty to their students to ensure their welfare," reiterating that "the duty of a host school to its own and visiting players in school-supervised athletic events is an exception to the general absence of duty." (Id. at pp. 162-163.) The court said, "California's abandonment of the doctrine of contributory negligence in favor of comparative negligence (Li v. Yellow Cab Co. (1975) 13 Cal.3d 804) led to a reconceptualization of the assumption of risk. In Knight v. Jewett (1992) 3 Cal.4th 296, a plurality of this court explained that there are in fact two species of assumption of risk: primary and secondary. (Id. at pp. 308-309 (plur. opn. of George, J.).) Primary assumption of the risk arises when, as a matter of law and policy, a defendant owes no duty to protect a plaintiff from particular harms. (Ibid.) Applied in the sporting context, it precludes liability for injuries arising from those risks deemed inherent in a sport; as a matter of law, others have no legal duty to eliminate those risks or otherwise protect a sports participant from them. (Id. at pp. 315-316.) Under this duty approach, a court need not ask what risks a particular plaintiff subjectively knew of and chose to encounter, but instead must evaluate the fundamental nature of the sport and the defendant's role in or relationship to that sport in order to determine whether the defendant owes a duty to protect a plaintiff from the particular risk of harm. (Id. at pp. 313, 315-317.) In Avila, the court held that "being intentionally thrown at is a fundamental part and inherent risk of the sport of baseball." (Avila, supra, 38 Cal.4th at p. 165.) Thus, the court held that a pitcher owed a batter no duty to refrain from intentionally hitting the batter in the head with the ball-a so-called "beanball" (id. at p. 152) (sometimes called "head hunting"). In that case, plaintiff alleged he "suffered . . . serious personal injuries." (Id. at p. 153.) In sum, in Avila v. Citrus Community College Dist. (2006) the California high court addressed a personal injury claim by a batter hit by a beanball (pitch intentionally thrown at a batter by a pitcher) during an intercollegiate baseball game. The batter brought claims against the community college district that hosted the game. (Id. at p. 153.) Applying the primary assumption of risk doctrine, the court observed that "the host school's role is a mixed one: its players are coparticipants, its coaches and managers have supervisorial authority over the conduct of the game, and other representatives of the school are responsible for the condition of the playing facility. We have previously established that coparticipants have a duty not to act recklessly, outside the bounds of the sport , and coaches and instructors have a duty not to increase the risks inherent in sports participation ; we also have noted in dicta that those responsible for maintaining athletic facilities have a similar duty not to increase the inherent risks, albeit in the context of businesses selling recreational opportunities ." (Id. at pp. 161?162.) The court held that the doctrine barred the claim against the school district. (Id. at pp. 163-166.) In Avila, supra, 38 Cal.4th at page 163, a baseball player struck by a pitch alleged that the school district breached its duty not to enhance the inherent risks in baseball by hosting a preseason game despite the rule prohibiting such preseason games. The high court rejected that claim, concluding that the district, in hosting the game, did nothing more than expose the plaintiff to the inherent risks of the sport. (Ibid.) The court also rejected the plaintiff's claim that the district breached its duty of care by failing to provide umpires under the theory that doing so "would have made the game safer" (id. at p. 166), reasoning that "the argument overlooked a key point. The District owed 'a duty not to increase the risks inherent in the sport, not a duty to decrease the risks.' " (Ibid.)