In Coates v. Newhall Land & Farming, Inc. (1987) 191 Cal.App.3d 1, Charles Coates was a dirt bike rider who signed a release agreement before using the defendant's motorcycle riding park. (Id. at pp. 3-4.) The release included an "advance waiver of liability" and an "express assumption of the risk." (Id. at p. 7.) While riding his dirt bike in the park, Coates was fatally injured. (Id. at p. 4.) His heirs sued the owners of the park for wrongful death. The owners were granted summary judgment based upon the release, and the Court of Appeal affirmed. (Id. at pp. 5, 10.) The court explained: "Behavior which is authorized is not wrongful and, logically, cannot be the basis of a wrongful death action. 'In its most basic sense, assumption of risk means that the plaintiff, in advance, has given his express consent to relieve the defendant of an obligation of conduct toward him, and to take his chances of injury from a known risk arising from what the defendant is to do or leave undone. ... The result is that the defendant is relieved of legal duty to the plaintiff; and being under no duty, he cannot be charged with negligence.' ." (Id. at p. 8, fn. omitted.) The Coates court's explanation indicates that 1 while the wrongful death cause of action is not derived from the decedent's rights, the pertinent duty of care is the duty of care the defendant owed to the decedent, which can be limited or negated by the decedent in a preaccident release. This rationale is also apparent in Horwich v. Superior Court, supra, 21 Cal.4th 272, which states that a "release executed by the decedent in circumstances involving primary assumption of the risk may also be asserted as a defense. In that situation, the decedent agrees in advance of the activity to relieve the defendant of any duty of care. The defendant can owe no greater duty to the heirs than to the decedent; thus the premise of any wrongful death action would fail at the outset." (Id. at p. 285, italics added.)