(1) In Forgnone v. Salvador Union Elementary School Dist. (1940) 41 Cal.App.2d 423, Cecelia Forgnone, an elementary student, was eating lunch in the classroom when she was "engaged by a fellow student in a scuffle which resulted in the twisting and breaking of her arm." (Forgnone v. Salvador U. E. School Dist., supra, 41 Cal.App.2d at p. 424.) No teacher was supervising this area. (Ibid.) Forgnone sued the school district alleging that it failed to take proper precautions for safeguarding the students of the school and that there was no supervision over this area at the time of the accident. (Ibid.) The appellate court concluded that these facts were sufficient to state a cause of action for negligent supervision. The court stated, "In the present case the negligence is alleged to have consisted of an omission to supply the supervisor of students during an intermission of school which is required by law. Since the accident occurred in a school room during the luncheon hour, it requires no speculation to assume that if the supervisor had been present in that room she would have observed the unusual scuffling and rough conduct of the students and she would naturally have commanded them to desist. Indeed, we may assume that if the teacher had been present the scuffling would not have occurred. Under those circumstances, with the supervision required by law, the injuries would not have resulted." (Id. at p. 425.) Further, the court stated: "We assume that the purpose of the law requiring supervision of pupils on the playgrounds and on the school property during school hours is to regulate their conduct so as to prevent disorderly and dangerous practices which are likely to result in physical injury to immature scholars under their custody. It is true that the mere lack of supervision, or inadequate supervision may not necessarily create liability on the part of a school district to compensate for injuries sustained by a pupil. If it appears that a supervisor could not have reasonably anticipated or prevented the conduct of fellow students which resulted in injuries, it might not be material whether they were present at the time of the act complained of, or not. But when the omission to perform a duty, like that of being present to supervise the conduct of pupils during an intermission while they are eating their lunches in a school room, may reasonably be expected to result in rough and dangerous practices of wrestling and scuffling among the students, the wrongful absence of a supervisor may constitute negligence creating a liability on the part of the school district." (Id. at p. 426.) (2) In Dailey v. Los Angeles Unified Sch. Dist. (1970) 2 Cal.3d 741, a student, Michael Dailey, died on the playground of a high school during the noon recess. At the time, Dailey was engaged in a "slap fight" with a fellow student. (Id. at pp. 745-746.) Slap fighting is "a form of boxing employing open hands rather than clenched fists and in which the object, at least initially, is to demonstrate speed and agility rather than to inflict physical injury on the opponent." (Ibid.) Dailey and his friend boxed unsupervised for 5 to 10 minutes while a crowd of students gathered to watch. (Id. at p. 746.) Suddenly, after being slapped, Dailey fell backwards, fracturing his skull on the ground, and died. (Ibid.) The teacher who was supposed to be supervising this area was in the gym eating his lunch and preparing for his afternoon classes with his back to the windows. (Ibid.) Further, a wall obscured his view of the area where the roughhousing was taking place. (Ibid.) This conduct was normal activity for the students at the school, but it could escalate into fighting if it was not stopped promptly when observed. (Ibid.) Dailey's parents sued the school district for wrongful death based on negligent supervision. (Dailey v. Los Angeles Unified Sch. Dist., supra, 2 Cal.3d at p. 744.) The trial court directed a verdict in favor of the district. (Id. at pp. 744-745.) The Supreme Court reversed. (Id. at p. 751.) The court stated: "While school districts and their employees have never been considered insurers of the physical safety of students, California law has long imposed on school authorities a duty to 'supervise at all times the conduct of the children on the school grounds and to enforce those rules and regulations necessary to their protection. ' The standard of care imposed upon school personnel in carrying out this duty to supervise is identical to that required in the performance of their other duties. This uniform standard to which they are held is that degree of care 'which a person of ordinary prudence, charged with comparable duties, would exercise under the same circumstances.' Either a total lack of supervision (Forgnone v. Salvador Union Elementary School Dist. (1940) 41 Cal.App.2d 423) or ineffective supervision (Buzzard v. East Lake School Dist. (1939) 34 Cal.App.2d 316) may constitute a lack of ordinary care on the part of those responsible for student supervision." (Daily, at p. 747.) The court continued: "Supervision during recess and lunch periods is required, in part, so that discipline may be maintained and student conduct regulated. Such regulation is necessary precisely because of the commonly known tendency of students to engage in aggressive and impulsive behavior which exposes them and their peers to the risk of serious physical harm. High school students may appear to be generally less hyperactive and more capable of self-control than grammar school children. Consequently, less rigorous and intrusive methods of supervision may be required. Nevertheless, adolescent high school students are not adults and should not be expected to exhibit that degree of discretion, judgment, and concern for the safety of themselves and others which we associate with full maturity." (Id. at p. 748.) "Recognizing that a principal task of supervisors is to anticipate and curb rash student behavior, our courts have often held that a failure to prevent injuries caused by the intentional or reckless conduct of the victim or a fellow student may constitute negligence." (Ibid.) Applying these rules to the Dailey fact situation, the Supreme Court concluded that "a jury could reasonably conclude that those employees of the defendant school district who were charged with the responsibility of providing supervision failed to exercise due care in the performance of this duty and that their negligence was the proximate cause of the tragedy which took Dailey's life." (Dailey v. Los Angeles Unified Sch. Dist., supra, 2 Cal.3d at p. 750.) There were three key facts underlying the court's holding. First, the department head failed to instruct his subordinates as to what was expected of them regarding supervision in their area. (Ibid.) Second, the teacher who was in charge of supervising the relevant area failed to "station himself in the office in such a fashion as to maximize his ability to observe the students outside, but sat with his back to the window. He did not devote his full attention to supervision but ate lunch, talked on the phone, and prepared future class assignments." (Ibid.) Third, neither of the teachers nearby "heard or saw a 10-minute slap boxing match which attracted a crowd of approximately 30 spectators, although this took place within a few feet of the gymnasium." (Ibid.)